Aloha, and how are you doing? Welcome to Ibachi Talk. Gordo, the tech star here. I'm here with my good old buddy, Andrew, the security guy. Aloha, everybody. Nice to see you. Welcome back. And we have our guest today who's read Brio, or you can say Brio, but that's not as Brio, right? Brio. Yeah, PhD. Nice to have you on the show, man. You're the first PhD we've had on the show. It's pretty courageous of you. Maybe I'm... Well, the show's leveling up. Yeah. Yeah, maybe, maybe. So anyway, please grab yourself a libation, pull up a chair, or a beach towel, and join us today for another exciting episode of Ibachi Talk. You're looking pretty cash today, dude. It's your birthday. I didn't work. It was your birthday yesterday. I leveled up. So your birthday yesterday, kinda nice. I was. 53. Ooh. Guess who else's birthday it is? I don't know. Hamish McGullible's birthday today. Actually, today. So one of our viewers, we have a viewer read, his name is Hamish McGullible. You're internationally... Yeah, he's... Yeah, there he is right there. There's his picture of him right now. He's sitting there right now in his back shed having a beer in his chainsaw. I thought he says beer, but it's beer. It's beer. Yeah, so there he is, Hamish McGullible enjoying his birthday. Happy birthday, Hamish. When's he coming on? We'll have to get him on. It's his fifth year anniversary of his pacemaker, too. How is he? You know, I have no idea. Better he's still working? It must be. He's still... It's your brother. Well, he sent me a text this morning. He's a loyal... He's a loyal, like, viewer. He's younger than I am, so that's all I am. Okay, good enough. I'm glad. I'm glad. So am I. I love that. So, we have come some segments. A couple of shows. A couple of bits. A bit and you know got one tech job. We have some news and stuff like that. Let's do it. I'm going to change things around. I like changing things around to make Zuri and Nick go crazy. Okay. So the script that you write, we never follow? Okay. I like it. Thank you. So, Brad, tell us a little bit about yourself. I moved to Hawaii following my previous job from Minnesota. From Minnesota? I can tell you're from Minnesota. Oh, Zuri's from Minnesota. She loves Minnesota. Hi, Zuri. And then I came here for, initially I came here for a project. Okay. And ended up falling in love with Hawaii. Oh, yeah, right on. And then I met my wife and we have kids now. This is home. This is home now. Amen. Love that. Been in technology for a while. Where'd you go to school? I went to school in Minnesota and then HPU, then Argus University. That's right. So he's alum like you and I. So we got three HPU alums. Three HPU alums. We love HPU. So, and I met you decades ago when you were with Sprint. Was it Sprint? I was with Sprint for a while. I think that we've worked on a project for the Syrian county. Yeah, police department. Police department. Which they're still using, I might add, today. They're still using to this day. Yeah. And fire department and EMS as well. Yeah. That was a great project working with Gordon. And I mean it. Yeah, right now. We all like working with Gordon because he's demanding, but he actually finishes things, you know. That's one of the goals of life, to finish things. That's right. What made it easy for us is he got it. Each time we said something, he got it. Yeah. So we did not have to.  I may have you on next week. He's not in charge of anything anymore, you know. You're looking for a coho spot. He never gives you anything nice. So what's our tomorrow? Tomorrow. You guys, don't work on weekends. Not the weekend. Not this weekend. Hey, so we got a little bit of background on red. So we have like some of our segments. So let's, we have this thing called, you know, got one tech job. So we find things that are happening around town or our friends sent to me. So what we got today, you know, got one tech job. So this is a shipment of meat that came to Hawaii. It's boneless pork rectums. I think they lost something in the translation. Isn't it called, isn't it called pork butts when you bite at the store? When I go to Safeway. They're inverted. It says inverted. What? Inverted. Oh, they're inverted. That makes it even better. I don't, I don't even, I don't, I'm at a loss. That's even funnier. I think when I finish here, I'm going to run and buy me some of... It's Chinatown just up the street. Wow. I'd like to see the recipe first for, you know... I'd like to see it. And it's a presentation, you know, like... That's what I eat. It's, half the meeting is about presentation. I mean, good lord. Oh my goodness. Okay, okay. So anyway, that wasn't very thematic about digital signage. Yeah, I'm not. Well, that was about signage though, because you know... So it's about signage. If you're reading that in your local grocery, keep moving down the aisle maybe, or maybe you have an affinity, I don't mind. That's content, and that's content. That's the point. Good point. Content has to be thought, well thought of. Yeah, that's it. So you're the president of 212 Communications. So tell us what, and I got news to do, but I still like to, I'm changing things around. I like this. So 212 Communications, so what is that? So 212 Communications is a digital signage company, but it started 2010. Okay. We approach this as signage from a different perspective, not like just content and displays, just to display that content. We look at it more from analytics perspective, from Internet of Things perspective, and how to make the digital signage also work for you. Almost, if you look at it just from a display and content, that's the basic. That's the basic. Yeah, like a menu at a store. So when you're talking about digital signage, we see things like that when we go around, right? We go to office buildings now, and they got digital signage with some stuff maybe on the bottom. Waikiki, I see a few in Waikiki that now are more, they do some advertising and they push some things at you, but there's nothing that says that it's related specifically to me. So are you saying that what you're doing is if I walk by your side, it's going to read my card off my wallet and say, hey, Gordo likes to go scuba diving, and boom, we're going to nail him with that? Well, we could do it, but now the security part of it does not allow us, because it may be illegal. But what we do is the user, the end user, or the customer or the guest that is using that digital signage, the experience for that particular person, we try to enhance it, try to make it better. We try to make the information that that person provides just by touching a screen, useful to the organization providing that digital signage. Instead of, I'm just reading the menu, if I have an interactive application that gathers in data and analytics, and I can take that information and present it to decision makers in a form of business intelligence, then it becomes more useful than just a display. So you're tracking where people are touching or where people are going. That's what we focus on. And you give that to the client. They say, hey, they're going to this particular location a lot. Now, why are they going there? Well, I love it first from the security perspective, because lobbies are an interesting place. People that are coming to a lobby need to be able to go where they're going, get that information quickly, maybe in a couple of different ways. Maybe they're hearing impaired or sight impaired, and so they're able to interact and get the information they need to go. But if a person who is just loitering in my lobby, he could be a problem from a security perspective. You're so paranoid. Yeah, I'm paranoid. A lot of times we have digital signage solutions and technology, but we also rely on the human factor to read and maybe take action. With the integration of Internet of Things, we can remove that human factor. For example, if there is a smoke detector integrated with digital signage, the minute the smoke sensor detects smoke, it changes the content, instructs people to leave the building, gives them the directions, and that way there is no panic. If there is another example, if there is an intruder, an active shooter, he can change the content from a safe and secure place and the student can go to the nearest room and lock yourself into security. You've got me thinking about this. It's brilliant when you think about it. If there is an active shooter in a particular location, boom, you change the signage and you tell everybody to go in that direction or where the active shooter or shooters are not happening. Some people shelter in place. Some need to egress. That's the good thing about having location tied to it is that it's cool. Now, we imagine if our police department, if our sheriff department have access to those signage... Before they get there. ...and the crime... See, it's a small thing that we never think about from a digital signage perspective. Now it's... It's a sensor. You mention safety and that's very, very important. So you get all of the organizations that are having digital signage participating in this... this effort to make things... Yeah, because it can become a sensor, right? It's gathering information as well. It can gather the analytics of how many people pass through. You can get traffic data. So now I'm taking this, the digital signage, we're going to dig deeper into it. My news segment has a little interesting overlap on that and I'm thinking of it now just as a result of our conversation. So, you know, Powerbox sends me information on these new things that they see happening. And one of the things they talked about was wearable trackers. So digital signage is kind of a form of wearable tracker except you're not wearing it, right? You're just going through it. But they were saying that the mobile health apps like your Fitbit, your Apple Watch, your Microsoft Watch, all those kinds of things that are tracking all of that healthcare stuff are somewhat behind the game when it comes to security. You've got non-HIPAA compliance and things like that. So these kinds of things are happening. So developers need to start looking at bringing that up. They've been kind of exempt from it. But I'm thinking now if I'm walking by a digital sign, if it can read my Fitbit, I mean I'm going extreme here, but if it can read my watch, which has my credit card and up comes an advertiser for a golf club or something like this, these are all kinds of things that can start happening with the Internet of Things. The other thing we also noticed is a lot of the stuff that gets bought, especially with the older people, they don't use it because they can't comprehend it. So the application developers have to move that up a bit. I think for a dead space, if you're waiting in an elevator, a lot of those are going to interact on the elevator. Some things you can gather data about other services that are available in the building that you might need or avail yourself of. I'm seeing in elevators, now you're walking in the elevator, they've got the video display up there. There's places for rent, suites for rent in the buildings. If there's a restaurant, they talk about the restaurant. It makes the perceived wait time a lot. It alleviates that perceived wait time. People don't like, they're quick and they have their phone, but if you can get them off their phone, they look up at the screen. They did a best study that said the best thing you can do in lobbies is put in mirrors because people like to look at themselves. That's not wait time because they're looking to see how stylish they are. Interesting. It depends on the industry where the digital signage is, hospitality, healthcare, and the privacy and ethics part of the technology has to be addressed. You're completely right. Let's hold that pause because we have to take a break. We've got to get Angus. He's got the security minute, but at the same time we can talk about that privacy and what's happening in the different audiences. We're talking about content. We'll grab Angus off the beach. He's at a new beach as you can see. We'll be back in a minute. Aloha, I'm Chantal Seville, the host of The Savvy Chick Show which you can watch every Wednesday at 11 a.m. on thinktechhawaii.com. On The Savvy Chick Show, we are all about inspiring and empowering women and girls to be the best they can be by having amazing guests from all around the world. So we hope you'll join us every Wednesday at 11 a.m. Aloha. I'm Jay Feidell and I'm here with Pete McGinnis-Mark to talk about HIGP and research in Manoa. What about that show, Pete? Research at Manoa really provides faculty members at the University of Hawaii with an easy way of explaining some of the research activities we're conducting on the campus. For example, I do a lot of space research, whether it's the moon and Mars, but many of my other colleagues do other interesting kinds of work, whether it's exploring the ocean floor in submarines, studying earthquakes and tsunamis or other activities. So research at Manoa really provides us with a way of telling the general public some of the activities which we're involved in, as well as communicating to our colleagues and students. This is a fun science and we really appreciate the activities which Research at Manoa enabled us to talk about. I love Research at Manoa. Come around, join us. It's Monday, one o'clock p.m. every single Monday. Be there or be square. Hi, my name is Justine Espiritu. This is my co-host, Matthew Johnson. Every Thursday at 4 p.m. we host the Hawaii Food and Farmer series. This is the place you can come to for insight on the perspective and history and passions of Hawaii's farmers and all folks involved in Hawaii's local food system. What kind of folks do we have on? So we have everyone from local farmers. We have foodies, chefs. We also have journalists, researchers, anyone who's actually working to help make Hawaii's local food system that much better. So join us every Thursday and tweet in the us and ask us some questions and leave your comments as well. Thank you. Hey, Aloha, and welcome back to Hibachi Talk. We found Angus on his... I don't think he was at a nude beach. I think it was just a nude beach. Angus, what's going on, buddy? How you doing, Erru? I dressed up today because we have a PhD in the house. You're looking good.  Thank you. Nice meeting you. Nice meeting you, too, that, buddy. You look very nice. Very stylish. Did you wear a suit in Thailand when you did your thesis? I wish I did. I wore an Aloha shirt, which I like. Awesome. Way to go there, lad. Anyway, I got a couple of wee things for you. We're ready for this. So anyway, I got my... Since we're doing signage and we're keeping thematic, this is the Scottish soup of the day. Oh, the sign of the day. Yeah, the sign of the day. It could be that, too, lad. Anyway, the Scottish sign of the day is like daily soup, whiskey. Good look. I love your people. It's similar in Inba. Heal Billy loves them, too. Anyway, I got a wee gadget. Kind of thematic, a wee signage thing. So have you seen these laser projected keyboards? I have, but I didn't think they worked too well. Anyway, it's a pretty cool thing.   That's awesome. It's got built-in batteries. It's got all kinds of really cool things. It works for your iPad, an iPad 2, an iPhone, and all the other kind of things. I gotta try that. It's not bad.  We've been on my Bitcoin. How much? $39.39. That's not bad. Not too bad. I'll give you a wee shot when we're out there. All right. There's no whiskey for you today. It's gonna be coffee. What do you mean no whiskey? What do you say no whiskey for me? Get this guest off the show. Sorry, sorry. I forgot about the priority. Yeah, yeah, please, please. My goodness. Anyway, everybody, remember you two read Aloha. Nice. Nice. All right. Angus, thanks for that. I don't want to check out the keyboard. Give us a shout. Let us know if it works for you. And whiskey for soup of the day. I don't know. Chancell. I got a little bit of security, man. We got a sign with some content on it. These things are so easy to break into. And I want you to understand that when you're reading a sign, still use your brain. Because humans in the West, we tend to think that the stuff we read is real. And it maybe isn't necessarily so. These devices right here that you see on the highway all the time, made by ECHO, realistically have a little keypad on a cord on the side of the sign. It should be locked. It may or may not be, but obviously it's easy to get in. And the password is DOT. You can find this anywhere on the internet. Department of Transportation. And so they're supposed to put another password in. But to reset the device, is two buttons that you hold down, which you can also find, which will reset the password to DOT. So, just be aware that signage is critical. So pay attention to signage in emergency situations, but also understand that some signs that you see, especially temporary signs, question that content, perhaps, if it seems odd. Because I don't think there were any zombie attacks. So we were talking about your two on two communications in your digital signage company and how different it is from a lot of the others, because of the analytics things that you're doing. What are the latest challenges? What are the fun projects you're working on? Some of the new projects we're trying, speaking of HIPAA. We're looking at a lot of in-home care, a lot of a lot of technology going all the way to following the patient. So we're trying, one of the fun projects is to a marriage between healthcare and digital signage. Although it's been around for a while. Another fun project, it's been also around for the last three years, location-based content. When you have tourists on a bus, or you have just a passenger in a cab, if I pass by an amount of shopping center and there is something going on in an amount of shopping center, the content will change automatically, let me know. I saw something like that in one of the Trump Towers in New York. I think Sprint was behind it way back in the day where I walked by a digital sign and they based, they would be able to determine where you had been in the shopping area and I was looking at lower shirts or whatever, and then there would be an ad that would come up on a trip to Hawaii. It might have been some facial recognition or something. So there is that's another fun project also is to just keep track of returning customers. You really get Facebook, right? They look at the face and then next thing you know you've been tagged in a photo somewhere. They've gone dual times, right? How long did you look at an item and then walk away and they track that and so then they'll offer you, they'll send you a price to your phone, you know, the lower price and that kind of stuff. I think when going back to what I said in the beginning of the segment is just making the experience of the end user better. We have new technologies in the digital signage industry, facial recognition, beacons, analytics and all that. At the end of the day if I as a user have a good experience at a retail store at a restaurant, at a hotel because of the digital signage then I think digital signage reaches its goal or reaches its objectives. If I walk just to the retail store and the minute I walk the digital signage because the motion sensor senses that I walked in and greeted me like welcome, we have this or if I'm standing in front of a product and the minute I pick up the product the content that pertains to that product started explaining to me then the experience becomes much, much better. So if you don't buy it or you do buy it then you start doing the analytics was the price or was it the packaging? And how long did you pay attention to the video and all sorts of things? There's a lot of that in retail I picked up the product, I listened to the information but I still did not buy it. That business intelligence based on analytics based on the technology based on the customer customer experience becomes very, very important. Just like we talked about in the beginning of segment is no longer just between with the picture and the price and it's definitely expanded beyond retail, so like I said health care is into it, even the financial centers everyone's worried about that customer experience because they're trying to keep their customer. Well I remember when Samsung came up with a TV and then the EULA they said that they were going to track every TV show you watched and whatever but no one reads the EULA and then everybody got really upset hey you're literally in my living room tracking everything that I do on your TV show. So you must wow how do you deal with the ethical ethical things that are ethical? When it comes to the legal side of it is a clear line. Either you're breaking the law or not breaking the law when it comes to the privacy and ethics then it's the responsibility of the service provider which is like us providing digital signage service to an organization and it's also the responsibility of the organization getting that information asking for that information. So you must have a lot of smart people within your organization that are sitting looking at not only the technology but then the application of that technology. I started the digital signage it was a friend of mine and I started it and we were both engineers. And to your point Gordon we needed to understand the business side of it, the privacy the security, the marketing all of the things that we did not stop and think about and my first step is to go back to school and get a PhD in business administration. And it seems like ever since I've known you you've always been learning and getting better. So believe it or not with all of that we have now burned through 30 minutes. I told you this would go fast. So 212 communications you got to check it out digital signage it is the wave of the future I can tell you right now you can bury your head in the sand and say it's not going to happen but it has already happened. But you take it to the next level someone like Reds Company would be pretty awesome. Anyway we also no guest goes unrewarded you get an autograph solo cup you know and I expect to see that on a digital signage somewhere down in the corner you got number 78 in the series. Episode 78 in my on our website and it's also going to be on our Facebook page. There you go, perfect. What more can we ask for? Anyway we want to thank everybody for joining us today on Think Tech and Hibachi Talk. Hamish happy birthday, Andrew happy birthday. Thank you. And as we say at the end of every show one, two, three. What are you doing?


For more videos on people's struggles, please subscribe to our YouTube channel. The world first heard about COVID-19 in December 2019. Since then, nearly every corner of the planet has been affected by this pandemic. Based on what media around the world is saying, it's hard to know what's true and what's not. Here are five key questions about China and COVID-19. Did COVID-19 originate in Wuhan? After the virus outbreak, many in the United States blamed the Chinese government for the global pandemic. President Donald Trump called it the Chinese virus. Western media blamed the Chinese people based on unfounded and racist claims. Although the first clusters were linked to seafood market in Wuhan, on March 17th, a U.S. study showed that the new coronavirus strain, SARS-CoV-2, had a mutation in its genes that was unseen in any coronaviruses found in bats or pangolins. It also refutes the claim that the virus was created in a Wuhan laboratory. The virus most likely came to humans many years ago, and there's no proof that Wuhan is a source of COVID-19. This is one of the many studies showing that there's still no scientific consensus about the origins of the coronavirus. Did China suppress whistleblowers of the virus? Western media has blamed China for repressing whistleblowers. But is this the truth? On December 30th, in the early days of the outbreak, two Wuhan doctors had suspicions about a patient report. They shared these suspicions with their colleagues via social media. Because they didn't follow medical protocol, they were reprimanded. But by the time this happened, the mysterious virus had already been under investigation. Days before the incident, Dr. Jiang Juxian, another Wuhan doctor, had already reported these issues. A national team of experts had already visited Wuhan, China's National Center for Disease and Control and the WHO had already been informed. China didn't want the world to forget Dr. Li Wenliang as the US politicians have tried to claim. In fact, the government since then has honored Dr. Li as a martyr, along with 13 other frontline workers. Did China fail to warn the world about COVID-19 until it was too late? Since the first cases of COVID-19 were reported in China, there are now over 6 million confirmed cases and 370,000 deaths globally. Did the Chinese government inform the world too late? On December 29th, the Hubei provincial authorities found out about the new coronavirus. This is a month after the mysterious symptoms were first reported. On December 30th, Hubei authorities informed China's Center for Disease and Control, or the CDC. The next day, the World Health Organization was informed. From February 16th to 24th, the WHO sent a team to China. In its report, the Chinese government and people were praised for doing their utmost to stem the spread of the virus. Meanwhile, the United States had long been informed about the severity of the problem. As early as January 3rd, the Chinese CDC officials called Dr. Robert Redfield, the head of the US Center for Disease Control and Prevention. But China's warning was not taken seriously. The CDC only informed the White House three weeks later, on January 25th. President Trump would only declare a national emergency on March 13th. Today, I am officially declaring a national emergency. Was China's response to COVID-19 authoritarian? Many around the world criticized China's measures as authoritarian when Wuhan went into lockdown on January 23rd. Once human-to-human transmission of the virus was established, movement of people in and out of the city was restricted. Wuhan would remain in lockdown for 76 days. An investigation found that if China had not taken these measures, there would have been 744,000 additional confirmed cases outside of Wuhan by day 50 of the epidemic. After visiting China in February, the WHO commended the Chinese response. Since then, country after country has gone into various forms and lengths of lockdown with a global spread of the virus. Did China's medical warning system fail to respond to COVID-19? Some say that China's medical system didn't respond in time to COVID-19. Learning from the SARS outbreak of 2002 in Guangdong Province, China set up a direct reporting system to catch any health emergencies before this barrel out of control. The system has a rigorous reporting procedure. Medical personnel report to their hospital administration, which then reports to the various levels of the Center for Disease and Control and the Health Commissions. This is exactly what Dr. Zhang Juxiang did on December 26th when she reported a mysterious virus in Wuhan. There is also no evidence that the Chinese direct reporting system was faulty. Instead, there is only evidence that the system, like any system, could not easily adjust to unknown or unclassified outbreaks. Having informed the WHO, China also shared the genetic sequence of COVID-19 with the world. This allowed for tests to be created and for vaccine research to begin. China has even made a commitment that the future vaccine will be a public good accessible to all. Although China was not fully prepared to respond to an unknown virus of this magnitude, its quick scientific and fact-based approach allowed for lives to be saved and for the rest of the world to repair. Read our study, China and Corona Shock, at thetricontinental.org.


Hello and welcome to the session in which we would look at federal tax authority. Specifically, we're going to be looking at the three sources of tax authority, discuss these parties, discuss their roles as they relate to federal tax authority. This topic is covered in an income tax course graduate or undergraduate level, the CPA exam, as well as the enrolled agent exam. Therefore, if you are a CPA candidate or a tax accounting students, I strongly suggest you check out my website farhatlectures.com. I don't replace your CPA review course. I don't intend to do so. I can I cannot do so, but I can be a useful addition to your CPA review course. I can add 10 to 15 points to your CPA exam so you can pass, move on and focus on your career. Your risk is one month of subscription. Your gain is potentially passing the exam. Are you willing to take that risk? And if not for anything, check out my website to find out how well or not well your your university doing on the CPA exam. I do have resources for other accounting, tax finance and other courses. Please connect with me on LinkedIn and check out my LinkedIn recommendation, like this recording, share it, follow me on Instagram and Facebook. So the first thing is we want to know it is a definition that's called because you know we want to know what is what is a substantial tax authority. A substantial tax authority is what is the authority. It's the sources that's going to tell us whether an item is taxable, deductible, includeable, executable from income, so on and so forth. So what is the tax authority? What's the source of it? Well there are three sources of tax authority. There are legislative law, administrative law and judicial law. And guess what? Since I have a list, I'm going to go over each one of these sections separately. And before we look at the judicial law, we're going to look at the audit process so we can tie it to the judicial law. Starting with the legislative law. Hopefully we all know what that when you think of the legislative law is basically the Congress, right? Legislative law, that's exactly what it is, part of it. So the legislative law is the law itself. It's the original source in contrast to the administrative and judicial, which we're going to see later, which are interpretation of the law, of the legislative law. So who who writes the legislative law? U.S. Congress, okay? Like for example, the Tax Cuts and Jobs Act was written by the Congress. Also, what's considered legislative law if the Congress issue any tax treaties, which is an agreement with another country between the U.S. and a foreign country. And the reason for it is to govern income, income earned in foreign countries. Therefore, we avoid double taxation, okay? Internal revenue code. The internal revenue code also is a legislative law because it's simply put coming from the U.S. government itself. It's a primary source of federal tax law. And hopefully you know this, the internal revenue code can impose on you all sorts of taxes, income tax, state tax, employment, excise tax, so on and so forth. Now we have something called Congressional Committee Report. Now, what is the Congressional Committee Report? Well, it sounds like something to do with U.S. Congress because congressional, it is something to do with the U.S. Congress, okay? Because when the U.S. Congress writes a law or sometime the language is ambiguous and when the law is initially published, it may not confuse, but some people may think there's a conflicting information in it. So what's going to happen? The Congress will issue this congressional committee report for what? To clarify the law. To determine the congressional intent. The keyword is intent. The intent that's behind the tax law. Therefore, people, not people, preparers, CPA lawyers, they know how to apply the law properly, okay? So basically, it gives you the reason behind the law and it helps you apply it, how to apply it. And obviously, the U.S. Constitution in theory is a legislative law, but usually the U.S. Constitution don't deal with tax law. So those are sources of legislative law. Let's move on to administrative law. And when you think of administrative law, think of the Department of Treasury, okay? Administrative tax laws are rules, regulations and procedures implemented and enforced by the Treasury Department. Now the IRS is a bureau of the Treasury Department. So the IRS comes underneath the Treasury Department. And when it comes to administrative law, we're going to look at seven things, I believe. Treasury regulation, revenue ruling, revenue procedures, private letter ruling, PLR, internal revenue bulletin, technical advice memoranda and IRS publication, seven, seven items. We're going to look at each one of these items separately, fairly quickly, but you need to be familiar with them on the exam. I'll try to make sense of them as much as possible, but that's the nature of the beast. It's basically a law you just have to know to memorize it at some point. Starting with the Treasury regulation, those are the official interpretation of specific code law. It's simply Treasury regulations are the highest administrative authorities issued by the Treasury Department, okay? Now bear in mind, the IRS is bound by these regulations because remember, the IRS is part of the Treasury. So of course, they are bound also court, accept them as long as they don't conflict with any other IRS regulation. Simply put, Treasury regulations are simple language, detail and relevant practical guidance. That's all where it is interpretation of the law. Revenue ruling, okay? And they are primary authority, primary authoritative source when conducting tax research and we'll look at that later. Revenue ruling, they're issued by the IRS, okay? Like regulation provide interpretation, but they don't. They do not have the force or bind the court by them. So they don't have the force of a regulation, okay? So although they are interpretation, but they are not as powerful as Treasury regulation because they provide a difference between revenue ruling and Treasury regulation. Rulings, they provide examples, an example or two about how the IRS will apply the law against a specific case. The regulation is basically an umbrella of rules. Like it tells you in most situations, this is what you use. Revenue ruling is looking for a specific case. So it gives you an example or two. Again, it's published by the internal revenue bulletin. We'll talk about internal revenue bulletin later on to inform and advise taxpayers, the IRS and other substantive tax issues. It's intended to promote the purpose of the revenue ruling uniform application of tax law by IRS employees and to reduce the number of letter ruling requests. So simply put, look, if you're seeing this case again and again and again, here's the answer for it. Here's the revenue ruling. Just let's use it and get done with it, okay? And to reduce something called the number of letter ruling requests. Now we're going to see what letter ruling request. So something will happen because we have too many letter ruling requests will issue revenue ruling because we're getting the same question again and again about the same topic. Well, let's issue a ruling and say this is how it should be done with and it becomes a revenue ruling. And we're going to see the difference between revenue ruling and letter ruling. So deal with common fact pattern. When we see there's a pattern, same questions coming up again and again. Let's give some specific guidance this way. When we get this question, we have an answer for it immediately. That's what revenue ruling is. It's also a primary authoritative source when conducting tax research. Revenue procedures are a little bit different. It deals with the internal management practices and procedures of the IRS. Now here we're dealing with like kind of not logistics but like red tape, red tape. For example, how to request a letter ruling, how to request a letter ruling, okay? So failure to follow revenue procedures, how to do it, it may delay the process, okay? It doesn't have, revenue procedures don't have the force of the law. Basically it's how the IRS run the administrations themselves. These are the laws you have to follow. You have to fill out this form, make sure it's signed, so on and so forth, okay? Now private letter ruling. So we're talking about letter ruling. It's specifically, it's a private letter ruling. PLR, you may see it in your textbook or in your review course. Here's how it is. You pay a fee to the IRS to ask the IRS how would you treat this proposed transaction. So it's a proposed transaction. It didn't happen yet but you just want kind of an advice or from the IRS. Therefore what you do is you issue, you ask them, look, could you please tell me how would I, how would I deal with this situation? Now if this same situation kept on coming with like how to treat stock options for example, which is really an old issue, or how to treat for example cryptocurrency transaction, okay? Something new, okay? If that questions kept coming again and again and a private letter rulings, people are asking, they're paying money for it, the IRS would say, oh there's a common pattern here. Let's issue a revenue ruling to give them the answer. Now if it's a private letter rulings, it only binds when they give you the answer. It binds you, the person that made the request and the IRS, okay? No other party can rely on it. Do not bind third party nor it can be used as precedent. Now although it cannot be used as precedent, but you can look at it for guidance, if you ask the question, they should give you the same answer. What the IRS does, they respond to multiple private letter ruling requests by issuing a revenue ruling. In this way, once we issue the revenue ruling, it binds all taxpayers and the IRS. Basically it becomes the rule because we see this issue coming back again and again. They just issue a rule this way. Everybody knows about it. Then we publish it and everybody will see it. We no longer get those same questions, okay? Where do we publish it? We can publish it in the Internal Revenue Bulletin. It's a weekly publication of the U.S. Revenue Service that announces official rulings and procedures of the IRS in publishing the Treasury Decision Executive Order Sex Convention. Basically anything the IRS wants you to know, what's going on in the Treasury Department, any court decisions, they will issue it in this Internal Revenue Bulletin. Now we have something called Technical Advice Memoranda or TAMS. Those are similar to letter ruling or the PLR, but deal with completed, not proposed. Now the transaction has been completed. It's in front of an IRS agent. They're looking at it and they don't know what to do. So it's issued to IRS field agent or questions rate by the taxpayer. Now it's not proposed. It's a completed transaction. So you will send your request to the National IRS Office and you'll ask them, could you please tell me what should I do in this situation? It cannot be cited as a precedent, okay? So basically it's again like a letter ruling because either the taxpayer doesn't know how to deal with this. They already completed the transaction nor the IRS agent who's handling, who's investigating. Therefore they need a little bit more help. Well, the National Office will issue them this TAM. Also we have the IRS publication. I hope you are familiar with IRS publication because in my tax course, I oftentimes, I ask my students to use them somehow in completing a, in completing the tax forms or completing a tax project. So you should be familiar with them, POP17, I hope so. Explain the law and plain language for taxpayer. A lot of people think it's not really plain language but they think it's a plain language. It highlight any changes in the law and provide examples illustrating different scenarios. It's a good source of information but it cannot be cited to sustain and position it, okay? So those are the administrative law, the seven items that compose administrative law. The next thing we're going to look at is judicial law. And when you think of judicial law, think of the court system, judges, okay? It's originate from the federal court system, the common law. It's primarily composed of court opinion. Court cases are considered a primary authoritative source when conducting tax research, okay? But before we discuss the judicial law, we want to know how do we get to the court system? So we're not going to just kind of jump, we file our return, we disagree with the IRS or the IRS they disagree with us. So we go to the court. It doesn't happen this way, okay? So let's go through the process. This way it's easier to understand the big picture. Let's discuss the audit process. So remember in the U.S., if you're not aware of this, if you're someone who's outside the U.S., in the U.S., the tax system is self-assessed and self-reported. Simply put, the IRS doesn't, you know, send us a bill every year. This is your tax. We prepare our taxes and we tell the IRS, this is how much we need to pay in taxes. Well, guess what?  So when they do some time, they audit us. They audit, you know, because the process is an voluntary process, especially voluntary in quote. It's not voluntary. You have to pay your taxes, but it's self-reporting, voluntary in that sense. So what they do as an enforcement, they can audit you. You can be selected to be audited for many reasons, okay? So what techniques would the IRS use to select your audit? One thing you can randomly select it, that tough luck, that's your chance, okay? So someone will select your case and guess what you are selected for audit. Now, for example, President Trump, he was selected for audit. No one knows whether it's manual, somebody selected it, or for other reasons, but that's way before he was president. Nevertheless, it's always a political issue. And I remember when President, is it when President Obama was an officer, it was a big deal about auditing a nonprofit organization. I believe it was funding the Republican Party. You know, my memory here is very fuzzy. And it was the same thing that, you know, it was politically motivated. The nonprofit was selected, you know, for political reasons, okay? So it can be randomly selected.  If somebody is targeting you, especially as government, you really don't want that, right? That's the last thing you want on your shoulders, okay? Or you can be selected statistically. The IRS, they have a software called Discriminate Inventory Function System or DEF. It basically, because they have so much data about the taxpayers and various returns, they know they should be able to predict what type of returns, what type of return profile they should have errors. It's not only what type of return they have errors. And they want the error to be in their favor. Then if they audit you, they spend time because the IRS don't want to audit you. If at the end of the day, they want to pay you back the money. If they want to audit you, they want the money. The US government wants your money. It's not the other way around. So the, so somehow they have a system that can determine whether this return has errors or not. And after that, it's going to be in our favor. What could be some statistical, some statistical indication? I mean, I'm just trying to give you an example that, you know, for example, if you have too many expenses in relationship to sales, for example, too much advertising or consulting expense in relationship to sales, and based on your business, because every business has a code based on that code, that's a high percentage. For example, that could be an indication that you either spending too much money or, or simply put, you are expensing stuff that you're not supposed to be expensing there. Okay, so there's an error. Now, obviously, they don't tell you what the system is. Otherwise, if they tell you, then businesses will be very careful. But sometimes they do provide other data that could help you, which we'll see in a moment, avoid being audited. Okay, but that deaf system, they could use to do that prior history with the IRS. If you were audited before, and obviously, if they found an error, there's a good chance they might audit you again. So it increases your chances of being reselected if you were audited before. If there's any discrepancy in what's reported to the IRS and your information, a good example will be your W2. For example, your W2 shows you should have 100,000 in earnings. You only reported 80,000 because your W2, your employer, sends the information to the IRS. The employer tells the IRS, this is how much we paid Mansour, 100,000. If you reported 80,000, and that, and by the way, all this information is automatic. And the reason I can comfortably say this, because I had my experience with this, I know my cousin, like when I was practicing, I completed his taxes. And I still remember, I transposed two numbers. I don't remember three and four, like his salary was, I don't know, $45,000, $34,000. I put $45,000, $34,000 instead of $43,000. And it triggered a discrepancy that, because it was all electronic, it's basically, his employer says he was paid this much. I'm showing them the return he was paid that much, and they don't match. It created a, there was a discrepancy. So because of this discrepancy, you can be audited. And the, too much itemized deduction, that's an obvious reason. If you have too much itemized deduction, like your taxes, it's not an issue anymore, because you're limited, if you have too much interest or charitable contribution, you might be selected. You might be selected because the IRS, they have millions, literally millions and hundreds of millions of taxes. And over the years, they have maybe billions of taxes. And they know on average how much the average US individual, if somebody's making $80,000, they usually contribute this much. If somebody's making $200,000, they usually contribute this much. They have a data for millions of people. Therefore, if one person is showing too much, too many itemized deduction, it doesn't mean they're committing fraud, but it's going to raise the IRS. It's going to raise flak with the IRS. Now, TurboTax warns you. For example, TurboTax, they'll tell you when you are preparing your taxes. Well, based on your income, this is what the average itemized deduction should be or charitable contribution, because that data is the IRS published it on, published it on a regular basis. Types of audit. What happened if you are audited? Okay, there's, you could be audited by mail or you could have a formal examination. Let's talk about both audited by mail. Simply put, this is not a big deal. Simply put, actually, I was audited by mail once in my lifetime. And that was in the year 2000. I still remember. And the reason I was audited by mail is simple, because again, audited by mail is when you're informed, you're reported and what somebody else reported, there's a discrepancy. I used to work with Merrill Lynch. So I'll tell you the story. It's funny. It's not funny, but well, it's sad, funny, but it's funny. So I was very immature. That was the year I graduated. So that year 2000, 2001, actually it was 2001, because I didn't get my bonus till 2001. So in 2001, I was, I was working in the stock market with Merrill Lynch. I get my bonus for that year. I was very happy. I invested everything in the stock market. And guess what? The stock market crashed and I lost all my money. Now, back then I was really, I did not know the law that much, the tax law. And I decided to do my taxes. So I know that you can deduct up to 3000 of capital losses. And back then you had to input everything. Now you input all this data electronically.  Back then what you had to do is you had to input every transaction manually. I'm talking about 2000, 2001. So as you know, I knew I can only deduct up to $3,000 in capital losses. I had more than $3,000. So what I did is I kept importing transactions until I reached $3,000 and I stopped. I said, okay, because the remainder, I will take in 2000, 2003, whatever remained, I will take it later, okay, against my future capital gain. But what happened back then, Merrill Lynch, which is my broker, when they send, when they send the information to the IRS, they only send the proceeds. In other words, they show proceeds, for example, let's assume they showed $50,000 of proceeds. Just I don't remember the number is, I'm not sure of whatever it was. Let's assume they showed 50,000 on my tax return, I was showing, for example, only 5,000. The reason I was showing like or 10,000. The reason I was showing only 10,000, because 10,000 minus 7 is 3,000 of losses. So all I wanted to show is 3,000 of losses. And I didn't really want to compute all of my losses. I was pretty angry with myself. So I said, well, I will do it later next year since I can, I can do this in the future year. So what they did, I was audited by mail. And basically they told me, I owe this additional money. So I said, not really, I have additional losses. Therefore what I had to do, I had to fill out my schedule D, my complete schedule D, send it to them. And I believe that was in 2000, 2000. They didn't cut up with me until 2003, but they eventually cut up with me. I was not trying to hide anything. I had the losses, simply I did not report them. And Merrill Lynch was showing I have more money than my costs. So that's all what it was. So it's not a big deal. Okay. It could be happen, you know, it doesn't match. Again, transposing numbers that what happened with my cousin, that could be a reason, information errors, the social security don't match or something like that. So this is corresponding by me. It's not a big deal. We send you the notice, pay it, or if there's any problem, fix it and send us send us the work paper. Okay. Now you could also have a formal examination. This is called the visitation audit. And they could visit you at your office. Oh, I'm sorry. It could happen at the Rosso office. They could invite you bring your paperwork and let's do the audit, or they can have a field office. They can come to you and audit you either at your business, your home, at your CPA firm or the paper is paperwork is or with at your attorneys. Now, if the issue is resolved by the revenue agent, that's good.  You sign something called form 870 waiver of restriction on assessment and collection of deficiency and tax simply put, you'd say, okay, the IRS agent, here's the IRS agent, they would say, okay, you owe us an additional 630,000. And maybe some of you are laughing now because you know what I'm talking about. Why am I saying this? Because if you watch Breaking Bad, this is what happened when Skyler, she acted dumb. She was the bookkeeper for Ted. If you watch the show and they were audited and Skyler acted as if she did not know what she was doing acted like dumb and the IRS agent gave him a break said, okay, you owe us the money. We're not going to proceed any further, pay the money because of your bookkeeper is not competent. And if you watch the show, it's really nice, nice show, really Breaking Bad, I like the show I watched it like maybe three times already. Yes, so Skyler, she acted dumb and she got head of the hook, but you know, they had issues later on. But yes, so that's what happened. They signed form 870, you pay your bill. And if they owe you money, they'll give you the money. But if you owe, you have to pay the taxes plus interest. And if you watch the show, Ted decided not to pay, then Skyler had to resort to Sol, Sol sent him his 18 to force him to pay. Ted had an accident, and you can watch the show yourself. Yes, so that's what it is. It was a field audit. And basically, Ted agreed to form 870, but he did not want to pay. So once you agree, you have to pay. So what happened if the issue is not resolved? If the revenue agent, you and the revenue agent did not resolve the issue, what they do, the revenue agent will give you a 30-day letter. And they would say, okay, you have 30 days to conduct an administrative appeal. Okay, you're not in court yet, and you conduct this administrative appeal with an officer, basically. Okay, so you go to the office of appeals, not the court yet, to resolve this issue before going to court. So once after the revenue agent is done, or the IRS agent, there is the administrative officer. If you can resolve the issue there, that's great. If you can resolve the issue with them, well, that's good. You will sign an 870 AD.  You resolve it. It's binding to all parties. You pay your bill just like 870 would have been binding if it was agreed with the revenue agent. So after the revenue agent, you have the administrative appeal. Okay, it's binding for everyone and it's done. If the issue is not resolved, you still, you know, you and the IRS are still in disagreement, they'll give you 90 days to pay the deficiency. Now you have notice of deficiency to pay, or you can file, listen to me carefully, with the US court. If you don't pay, if you don't want to pay, you can file with the US court. If you want to file with any other court, other than the US court, you have to pay. Without paying the bill, you can only file with the US tax court. We're going to discuss this in a moment. So the notice of this notice of deficiency would say, okay, now I'm going to go through the court system. Now you're going to go through the court system. Okay, to file another court, you need to pay the bill first. So remember the only place where you can, I'm going to repeat this several times. The only place you can file a case is in the US court without paying your bill. You're going to get sick of me the next five minutes saying the same thing. Okay, so here's how the court system looks like, our court system. So first you start at the lower court. What are the lower court? We have the US tax court. We have the US district court and we have the US court of federal claims. Okay, those are the three courts and we're going to discuss each one of them separately. This is where you start. Well, if you don't like the decision, you can appeal. For the first two court, the US tax court and the US district court, you would appear to the US court of appeals, there's 12 of them. For the US court of federal claims, you would appeal to the US court of appeals federal circuit. So this is what happened. Okay, then if you are not happy with these appellant courts, what you can do is you can appeal to the Supreme Court, sell them, not sell them rarely or the US Supreme Court will hear a tax case. I mean, many cases are appeal to the US Supreme Court, but the US Supreme Court, they don't have time for all these cases because they have so many other issues, they sell them. They sell them here at tax courts, but this is just showing you how it works. If the Supreme Court declined to accept it, then guess what? Then whatever the US court of appeals decided will go with that decision. It doesn't mean the US Supreme Court agrees with that decision, just simply the US Supreme Court don't have time to look into it. Okay, so the appellant decision holds. Now, if the IRS decided to listen to the case, it will issue a writ of, here's my writ of cert or writ of certiori, certiori. Well, my Latin is not that good and they will accept the court and they would look into it. So this is the overall picture. So most civil tax cases, in most civil tax cases, the taxpayer has the burden of proof, which is, and it doesn't have to be unreasonable of doubt, they have to show preponderance of evidence, which is more than 50%, more than 50% chance that they are right. Now, we're going to discuss each of these courts separately, advantages and disadvantages, why would you file in one and not the other. Basically, we kind of knew why we would file in the US tax court, starting with the US tax court. As the name suggests, look, sometimes the name would reveal itself, US tax court. And guess what? It only handles what type of cases? Tax cases, you got it, easy to remember, US tax court. Just look at the name. And the good thing about the US tax court, you don't have to pay the file. So you can file, say, you know, I disagree, I'm going to file, and I'm not going to pay yet until the court is done. There's no jury in this court. So the judge, maybe an expert, the CPA, former CPA, or a judge that has, you know, some type of PhD or a master's in taxation will hear your case. They do have a small cases division, basically, they do have a small cases division, like a different division. And if you accept to go there, there's no appeal, whether you lose or you win, it's done, it's a final decision. Okay. Now, the US tax court have to issue two type of decision, and you need to be familiar with them. One is a regular decision. Regular decision means that decision, it's a new case where a new precedent is established. Remember, our tax, our court system, once they decide a case, and it's a new case, it becomes a precedent, it becomes the law. If it's a new case, it's called a regular decision. And that's important. That's a big thing. If you win a case, it means you basically changed the law. Now the law is your case. Everybody's going to look at your case as a precedent. If it's not a new precedent, it's called a memorandum. Basically, the judge applied existing law or existing precedents, and it has little value as far as tax law is concerned, because it already existed. All what the judge did is apply the existing law. So this is the US tax court. Again, if you're not happy with their decision, you can go to the US court of appeals, US court of appeals, the regional circuit, which is 12 of them. Or you can start your decision with the US district court. Here you can have both civil and criminal cases, you're not limited to taxes. Notice, because US tax court is limited to taxes. Okay. There's one court per state, at least remember, it's a district. Look at the name of it, district court. I think it's a location. So each state will have at least one. Some states will have more. Okay. Simply put, because it has to do with the jurisdiction, the district of where you are operating or living. You could either choose a jury or a judge to oversee the case. You'll have to pay your bill first here. And this is the disadvantage. You have to pay your bill. And sometimes those are millions and millions of dollars. Okay. The third court is the court. And again, if you're not happy with the US district court, you will go the regional circuit, which is US court of appeals. Notice the regional, just like here's the tax, and the district goes to the regional court of appeals. The US court of federal claims, this court will hear any claim for money against the United States. Okay. It's located across the whole country. It's the US court of federal. So it could be anywhere in the country. There are 16 judges. Okay. Here your judge will, your lawyer will have to select what's the best court to file because they have to use their judgment basically, their skills. There's no jury. So basically a judge will decide and there are 16 of them. And I'm not sure if you follow the news, but President Trump basically appointed any and every judge he could have in those court system. No jury. And you have to pay your bill first as well. So you need to know the difference between those courts. Just know that US court of federal claims, if you're not happy with the decision, it goes to the US court of appeals, the federal section of it. Okay. Also, we need to know the hierarchy of authority because notice we have so many different authorities here of tax authorities. So let's go through them in a hierarchy, hierarchical perspective. The highest authority is the US Constitution, which is we don't, you just don't worry about this because it doesn't deal directly with taxes. Next comes IRS or internal revenue code in the United States Supreme Court. Again, also think of the Supreme Court, they really don't, they get don't, they don't get involved with tax issues. But in theory, they can, if the cases appeal to them, and they accepted the case, remember RIT of cert, they will accept it and they will look into it. And if they make a decision, the decision will becomes the highest authority. Okay. Now let's assume, let's for the sake of some sake of illustration, if there is a case where it appeared with the US Supreme Court. So yeah, now you have US Supreme Court decision, IRS decision. Well, which one is the latest? Most probably it's the US Supreme Court will override the internal revenue code. Then comes the Treasury Regulation and Appellant Court opinion, same concept, same concept. If you have both the latest decision, if the court opinion is the latest decision that will override the Treasury Regulation, if the Treasury Regulation is the latest decision, it will override the Appellant Court opinion. Then we have the US Tax Court, US District Court and the Federal Claims Court. Okay, there are, again, in hierarchy, we're going down, we're going down the hierarchy. So any decision by the Treasury Regulation would override those court. Any decision by the court of Appellant Court would override those courts. The US District Court, the Federal Claims and the US Court. Then we have the revenue rulings, which we talked about and revenue procedures. And at the end, private letter rulings and others. So notice, when you are on the same level, the latest one in times of one was at issued last is with override. So revenue rulings would override revenue procedures if they are discussing an issue and it's in both. But if the revenue rulings came last, it will override it and same thing with revenue procedures. And basically, this is all what I'm going to go over in this session. That's basically just knowing what parties are involved, the roles, what are they responsible for, what type of rules they can issue. That's basically what it comes down to. If you're studying for your CPA exam, again, I'm going to invite you to check out my website, farhatlectures.com. I do have my lectures, my resources aligned with your CPA review course. So it's easy to follow. Again, I don't replace your course. I can be useful edition. I can attend the 15 points to your CPA exam by helping you understand the material differently than your CPA review course. Your risk is one month of subscription. Your gain is potentially passing the exam. Be confident, study hard, stay safe.


Hey y'all Dustin Shepherd here. We're gonna talk about keto up ketones in a can y'all Super super excited about this. This is this is a little bit of my pleasure. I like carbonation So that's part of why I like it so much But who what when where why should you use this and what's it all about? So basically it's kind of like a lifestyle This is something that's easy on the go I drink I drink my keto nap in the morning every morning If you haven't seen that video yet get up there and check it out. This is a swap out You can swap this for that. It's a cool. It's an even swap But what makes this a little bit different? Partly is carbonated And as caffeine in it like keto not only has caffeine has caffeine and caffeine free this only has caffeine in it At this point, maybe we'll come up with a caffeine free one, but right now that's all we have in there And what we what we see with this product is it up takes really quickly into the brain And so you start to feel it kind of like the Mexican heat guns you kind of feel a little faster Which is really cool and I think has to do with the caffeine carbonation combined But it's really neat. I use this as like a pre-workout or if I'm just running out of the house And so like I said, I like carbonations. That's really all I use it I use it for is a pre-workout either this or unleashed and then I use it when I'm just running out the door And I want some ketones on it The flavors are a little different because it's formulated differently with the carbonation tastes a little differently But this is a great little support product I love it. I always have it on hand when people come in to visit. This is something that's easy They just want it like they'll grab this before they'll grab like a pack and make it into a water bottle or a shaker bottle This will does is grab out of the fridge and they'll just drink it And so it's kind of cool because my friends get to have ketones And they're just driving a can that like what they normally would have and so this is a great alternative for people that love like the Monsters the red bulls net that carbonation and feeling that the difference is is that this has real energy in it Not just caffeine It's healthy for them. It's super low carb It's gonna help with food cravings and everything else is given all the benefits of ketones and not all the crap that goes with those other products So this is a huge cool game changer for people. So check it out So whoever invited you to check this out and get back to them You can get it from them if it's available. We had to go through a huge shift So depends on when you're watching this video. If not, you'll have to just wait for it like we do But it's an unbelievable resource unbelievable product. You got to check out. You got to try You remember we're a huge community and team. So reach out to me. Let me know if you have any questions Let's take care of you We're gonna plug into you as much as you plug into us and we're gonna give you the guidance you need The information is here. We just want to support you in your journey the best we can so appreciate you all and have an unbelievable day. Cheers


Good day ladies and gentlemen, welcome to our next dissection. This is Dr. Sanjay Sanya going to demonstrate the kidney in the supraenial glands Welcome to our second Dissection in the series now. I'm going to demonstrate the kidney the ureters and the supraenial glands These are also retroperitoneal structures first of all the location of the kidney as you can see the right kidney is Situated slightly lower than the left kidney and that is because of the right lobe of the liver We all know that the approximate location of the kidney is from T3 T11 to L3 But there's a one centimeter one vertebral segment mobility up and down depending on posture for the right kidney But here we will see something more interesting, which I'll tell you later. So this Is the location of the right kidney and this location is called the para vertebral gutter This depression that you see here is called the para vertebral gutter and this is the right side and this is the left side So therefore the orientation of the kidney is slightly oblique This is the upper pole of the kidney. There's a lower pole and this is the region of the High lobe and this space that you see between the anterior and posterior surface is called the renal sinus Similarly, we can see the same things here and it is filled with fat It was covered by perinephric fat, which I have removed here and this fat that you see on the posterior This is the para renal fat, which is outside the renal fascia. I have removed the renal fascia I removed the perinephric fat Now let's take a look at the high lobe and see what are the structures which are entering or leaving the high lobe So this is the high lobe of the right kidney So as we had mentioned previously, this is the renal vein. So this is the right renal vein Let's just remove these fascia and you can see this is the right renal vein The right renal vein as we had mentioned is smaller than the left renal vein and it's very thin. This is the anterior most structure Just behind the right renal vein We see the renal artery here The renal artery right side is longer than the left side for obvious reasons and After that, we had already mentioned in class that the renal artery divides into five Segmental arteries and some of those segmental arteries you can already see here You can see one of the segments here. You can see another segment here You can see a third segment here We had mentioned five segmental arteries of the right renal artery depending on the five segments of the kidney Now let's take a look at the third structure and that is this one This is the pelvic Kalecial system and we can see emerging posterior to the renal vein renal artery is the renal pelvis and If you dig deeper, you will see that it is the pelvis is dividing into major calyx and it will divide further into minor calyxes And this is the pelvic uretric junction. Let's trace the ureter down The ureter goes down approximately five centimeters from the tips of the lumbar vertebrae and it goes down So this is one side of narrowing at the pelvic uretric junction as it descends down if you notice it crosses The common iliac artery at the pelvic brim. So that is another side of narrowing And after that it goes into the pelvis and there is also a third side of narrowing when it enters the urinary bladder Okay, so that is about the right side Now let's take a look at the left side Again, we see the same structures. We can see this is the renal vein here anterior left renal vein is obviously longer And just behind that this structure that you see here is the left renal artery Which is smaller because the ureta is on the left side and the same thing if you dig deeper you'll find that it divides into its segmental branches and posterior to all these two structures you will find that this is the pelvis Renal pelvis continuing down as the ureter. I have removed the uretric fascia I told you you can see a little bit of the uretric fascia here and I told you that the blood vessels of the ureter are in a peri uretric fascia and We have to preserve the fascia in real life. Otherwise, we will get ischemic necrosis Here also it follows the same course along the tips of the lumbar vertebrae and then it crosses The common iliac artery here at the pelvic brim the left common iliac and then it enters into the pelvis and to the Okay, so that's about the kidney and the ureter In this kidney incidentally you can notice that it is slightly lobulated, which is a common occurrence You can see that the kidney is not exactly being shaped as we mentioned the classical It is slightly lobulated some some of these actually are persistence of the fetal lobulations Okay, now I would like you to notice something very interesting. You're naturally wondering where is the supra renal? Remember the right supra renal is pyramidal in shape. The left supra renal is more like a French cocked hat. This is the Left supra renal it is located on and it is situated more medially It is in relation is very close to the left renal vein So this is the left supra renal vein and you can see that this is the Left supra renal gland and you can see this is the left supra renal vein draining into the left renal vein This is the supra renal gland. This is the supra renal gland this one So those of you who have not seen this is the supra renal gland and We have already seen that this communicates with the left inferior phrenic vein and you can see a communication going and that is the communication with the left inferior phrenic vein. So this is the left supranial vein which is draining into the left renal vein. So this is the left supranial gland. It is situated in the upper pole of the left kidney. Let's take a look at the interesting thing about the right kidney. We notice that the right kidney there is no supranial gland. Clear? So you're wondering where it is. It is stuck to the under surface of the diaphragm and here it is. This is the right supranial gland and I did mention in class that sometimes when the kidney descends down there is a septum between the kidney and the supranial. So therefore if the kidney descends down the supranial remains in place. Here the kidney has gone down a little bit and so therefore the supranial gland is still in place. It is stuck to the under surface of the diaphragm and this is the right supranial gland and this is roughly pyramidal in shape and incidentally you can see that the right supranial gland is also draining and this is the right supranial vein which is draining into the inferior vena cava and you can see that here. This is the right supranial gland. So both the supranial glands are attached to the under surface of the diaphragm by Mr. Fascia and they're separated by means of a septum from the respective kidneys. In this case there's a distinct gap between the two because the right kidney has descended down a little bit. So these are the salient points I wanted to show you about the kidney. Now before I conclude because the kidney is located in the paravartibral gutter it is located slightly obliquely. There is a tendency for urinary stasis to occur within the pelvic licea system and the patient is recumbent for a long period of time and that tendency for recumbency produces what is known as urinary stasis and that stasis needs to urinary calculus formation and when the calculus fills up the pelvic licea system it forms what is known as staghorn calculus. So it is this oblique position of the kidney in the paravartibral gutter which predisposes to formation of stasis and urinary calculus formation. I'm opening the right kidney along its convex lateral border to show the pelvic licea system. Now I've cut through the cortex. I'm deepening with finger dissection and I'm opening out the pelvic licea system. There you go and this is the interior of the right kidney. Okay let me just mop it up and we will see the parts of the interior of the kidney. So we can see that these are the medullary rays, the medullary, this is the pyramid, this is the pyramid and in between this is the renal columns of Bertini. These are the medullary rays which contain the collecting ducts of Bellini. This is the medulla and this outer portion that you see is the renal cortex which contains the nephrons, the proximal convoluted tubules, distal convoluted tubules, the loops of Henley and these medullary rays are the collecting ducts. The tips of the pyramids are known as the papilla and the papilla then communicate by this concave structure here which is the minor calyx and that is where filtration of urine takes place from the pyramids papilla into the pelvic licea system. These are some of the fat structures which are also present inside the renal sinuses and if you remove them we should be able to see the pelvic licea system and here we go. We can see the pelvic licea system on this side. We can see the minor calyx here, we can see another minor calyx here, we can see some more, we can see they're uniting to form the major calyx and more major calyxes will unite and they will form the and this is finally coming out as the the renal pelvis here. So this is the renal pelvis there. This is where it is forming the renal pelvis. This is the pelvic licea system and you can see it very clearly here. That is the point I wanted to emphasize and about this particular kidney. Thank you very much for watching ladies and gentlemen. Have a nice day. Thank you.


Whole Story Audiobooks presents All of Us by A. F. Carter Narrated by Sarah Borges Prologue When Sergeant Louis Brady pulls up to the intersection of President and Neven Streets in Brooklyn, he finds three unmarked Ford Escorts. Practically his entire squad, haphazardly parked, knows to curb. Already pissed, he parks his ancient Grand Marquis next to a fire hydrant and gets out. The contrast between the unusually crisp July air and the smoke-saturated interior of the Grand Marquis strikes him immediately, though he's not sure which atmosphere he prefers. He does know that his vice-unit is out of business in this neighbourhood, with no arrests to show for the effort. Lieutenant Cathcart will not be happy. Brady holds up a hand when patrolman Anthony Roboda approaches.  For cops like Roboda, a simple prostitution sting can become a crusade to rid the world of impurities. Brady, by contrast, doesn't hate, doesn't even dislike the women and the transvestites he arrests.  In twenty years comes the magic pension. Brady's entire career has been based on this understanding of his role in the war against crime. Brady waves at the four cops standing by their units. Tell those bastards to get back to work, Anthony.  He doesn't wait for a reply, but instead approaches the Ford with the woman in the back seat.  Her already short skirt is drifted up, probably when she backed into the car. Now it rides almost at her hips, while her green blouse, sheered to begin with, is unbuttoned far enough to reveal a lacy pink bra that Brady wishes he'd given to his wife last Christmas. Brady stops a few feet from the car. The sight's so wonderfully erotic he wants to prolong it as long as possible. He's assuming the woman is too preoccupied with her situation. She's not handcuffed, but the doors can't be opened or the windows roll down. To realize she's being watched.  Does she find what she's looking for? Sample complete. Ready to continue?