Title

Text Resize
Print
Email
Subsribe to RSS Feed

Wednesday December 19, 2018

Private Letter Ruling

IRS Rules on Stock Donation

GiftLaw Note:
Taxpayer A is the sole settlor and trustee of a revocable trust (Trust). Trust is the sole member of LLC 1, which is a disregarded entity for federal income tax purposes. LLC 1 contributed shares of Stock 1 of Corporation 1 to a Sec. 509(a) private foundation (Foundation). The value of the contributed shares does not exceed 10% of Corporation 1's outstanding stock. Stock 1 is listed and regularly traded on a public national securities exchange. Taxpayer A and Taxpayer B are managers of LLC 1 and are subject to Corporation 1Hs insider trading policies. LLC 1 agreed not to take any action that would restrict the ability of Foundation to sell the shares of Stock 1. The shares of Stock 1 are not subject to any restriction that would affect the value of the shares or prevent the shares from being freely traded. The shares of Stock 1 have been held as a capital asset for more than one year and the fair market value of the shares is higher than the shares' adjusted cost basis. Taxpayer A and Taxpayer B request a ruling that the shares of Stock 1 constitute qualified appreciated stock within the meaning of Sec. 170(e)(5)(B).

Section 170(e)(1)(B)(ii) provides that the charitable deduction for contributions of property to Sec. 509(a) private foundations must be reduced by the amount of gain which would have been long-term capital gain if the property had been sold by the taxpayer. Section 170(e)(5) provides an exception for this general rule. Under Sec. 170(e)(5), deductions for contributions of qualified appreciated stock will not be reduced to basis but rather will be based on the property's fair market value. Section 170(e)(5)(B) defines QAS as any stock of a corporation (i) for which, as of the date of the contribution, market quotations are readily available on an established securities market and (ii) which is capital gain property. However, under Sec. 170(e)(5)(C), the QAS exception will not apply to the extent that the amount of the contributed stock exceeds 10% of all of the corporation's outstanding stock. Here, the Service found that the Sec. 170(e)(5) requirements were satisfied and, therefore, the stock contributed to Foundation constitutes qualified appreciated stock within the meaning of Sec. 170(e)(5)(B).
PLR 201848005 IRS Rules on Stock Donation

Dear * * *:

This responds to your letter dated March 2, 2018, and supplemental letter dated April 30, 2018, requesting a ruling under § 170 of the Internal Revenue Code (the Code). Taxpayer A and Taxpayer B (collectively "Taxpayers") request a ruling that the Contributed Shares of Stock 1 of Corporation 1 indirectly contributed by Taxpayers to Private Foundation constitute "qualified appreciated stock" (QAS) within the meaning of § 170(e)(5)(B) of the Internal Revenue Code.

FACTS


Taxpayer A is the sole settlor and trustee of Trust 1. Trust 1 is wholly revocable by Taxpayer A. Trust 1 is the sole member of LLC 1, which is a disregarded entity for federal income tax purposes. Taxpayers are managers of LLC 1. LLC 2 is a wholly-owned subsidiary of LLC 1. Corporation 2 is an organization described in § 501(c)(4). LLC 2 has the power to designate the members of Corporation 2's board of directors. Taxpayer A is also the sole settlor and trustee of Trust 2.

On the Contribution Date, LLC 1 contributed the Contributed Shares of Stock 1 of Corporation 1 to Private Foundation. Private Foundation is a private foundation within the meaning of § 509(a) but is not considered a private foundation described in § 170(b)(1)(F). Taxpayer A is the sole trustee of Private Foundation.

Stock 1 of Corporation 1 is listed and regularly traded on Exchange, a national securities exchange registered with the Securities Exchange Commission (SEC) under section 6 of the Securities Act of 1934 (the Exchange Act). Additionally, Taxpayers state that the Contributed Shares could at all times on or after the Contribution Date be sold on Exchange at Exchange prices pursuant to an exemption from the registration requirement set forth in section 4(a)(1) of the Securities Act of 1933 (the Securities Act) and the safe harbor set forth in SEC Rule 144.

Taxpayers, and entities over which they exercise control, are subject to Corporation 1 insider trading policies that require Taxpayers and such entities to conduct purchases and sales of Corporation 1 securities pursuant to SEC Rule 10b5-1 written trading plans.

In the instrument effectuating the contribution of the Contributed Shares, LLC 1 agreed not to take, and to cause any person with which it would be required to aggregate sales under SEC Rule 144 not to take, any action that would restrict the ability of Private Foundation to sell the Contributed Shares as a result of the volume restrictions contained in SEC Rule 144(e).

Neither the exemption to the registration requirement, nor an SEC Rule 10b5-1 written trading plan, nor the SEC Rule 144(e) volume restrictions subject the Contributed Shares to a restriction that materially affects the value of the Contributed Shares to the donor or prevents the Contributed Shares from being freely traded.

1. Taxpayers' beneficial ownership of Stock 1 and Stock 2 of Corporation 1 has not materially changed during the period beginning on Date 1 and ending on the date of this ruling request.

2. The Contributed Shares were at all times held as a capital asset, as defined in § 1221(a), in the hands of LLC 1.

3. On the Contribution Date, the adjusted basis of the Contributed Shares was lower than the fair market value of the Contributed Shares.

4. On the Contribution Date, LLC 1 held the Contributed Shares for more than one year.

5. None of Taxpayers, Trust 1, Trust 2, LLC 1, LLC 2, Corporation 2, or Private Foundation are or have ever been an "issuer" of Corporation 1 securities within the meaning of the Securities Act.

6. None of Taxpayers, Trust 1, Trust 2, LLC 1, LLC 2, Corporation 2, or Private Foundation are or have ever been a "dealer" within the meaning of the Securities Act.

7. The Contributed Shares are "restricted securities" within the meaning of SEC Rule 144(a)(3).

8. Each of Taxpayers, Trust 1, Trust 2, LLC 1, LLC 2, Corporation 2, and Private Foundation are "affiliates" of Corporation 1 within the meaning of SEC Rule 144(a)(1).

9. None of the Contributed Shares are or will be subject to an effective registration statement within the meaning of section 5 of the Securities Act.

10. On the Contribution Date, each of Taxpayers, Trust 1, and LLC 1 could satisfy all requirements under SEC Rule 144 to sell on Exchange at Exchange prices a number of shares of Stock 1 of Corporation 1 equal to the number of Contributed Shares.

11. On the Contribution Date, Private Foundation could satisfy all requirements under SEC Rule 144 to sell on Exchange at Exchange prices a number of shares of Stock 1 of Corporation 1 equal to the number of Contributed Shares.

12. Private Foundation expects to be able to satisfy all requirements under SEC Rule 144 to sell on Exchange at Exchange prices Stock 1 of Corporation 1 at the times and in the amounts contemplated by Private Foundation's Approved Plan.

13. Following LLC 1's contribution of the Contributed Shares to Private Foundation, Taxpayers, Trust 1, Trust 2, LLC 1, and LLC 2 will not have gifted in aggregate more than ten percent by value of Corporation 1 stock to Private Foundation, taking into account prior gifts of Corporation 1 stock by such persons to any private nonoperating foundation.

14. Other than as described in this ruling request, there are no legal restrictions on the ability of Taxpayers, Trust 1, LLC 1, or Private Foundation to sell or otherwise dispose of the Contributed Shares.

15. On the Contribution Date, Taxpayers did not possess any material nonpublic information with respect to Corporation 1.

16. LLC 1's contribution of the Contributed Shares to Private Foundation on the Contribution Date, during Taxpayers' Year 1 taxable year, constituted a "charitable contribution" within the meaning of § 170(c).

17. At all times, Taxpayer A, as trustee of Private Foundation, will engage in reasonable best efforts to ensure that the amount of Corporation 1 stock held by Private Foundation does not exceed, when aggregated with all other private foundations described in § 4946(a)(1)(H), two percent of the voting stock and two percent of the value of the outstanding shares of all classes of Corporation 1 stock.

18. Any sales of the Contributed Shares pursuant to Private Foundation's Approved Plan will occur via open market transactions on Exchange, and, to the best of Taxpayers' knowledge, will not be sold to any person related to Taxpayers or any entity controlled by or related to Taxpayers within the meaning of § 267.

19. Taxpayers will value the Contributed Shares for purposes of the value of their deduction under § 170 at the Contributed Shares' market value on the Contribution Date by calculating the average price between the highest and lowest quoted selling price on Exchange on the Contribution Date.

LAW AND ANALYSIS

Internal Revenue Code and Income Tax Regulations

Section 170(a) allows a deduction for any charitable contribution (as defined in § 170(c)) payment of which is made within the taxable year. A charitable contribution shall be allowable as a deduction only if verified under regulations prescribed by the Secretary.

Section 1.170A-1(c)(1) of the Income Tax Regulations provides if a charitable contribution is made in property other than money, the amount of the contribution is the fair market value of the property at the time of the contribution reduced as provided in § 170(e)(1) and § 1.170A-4(a).

Section 170(e)(1)(B)(ii) provides that the amount of any charitable contribution of property to or for the use of a private foundation as defined in § 509(a), other than a private foundation described in § 170(b)(1)(F), otherwise taken into account under this section shall be reduced by the amount of gain which would have been long-term capital gain if the property contributed had been sold by the taxpayer at its fair market value (determined at the time of such contribution).

Section 170(e)(5)(A) provides that § 170(e)(1)(B)(ii) shall not apply to any contribution of QAS. Section 170(e)(5)(B) defines QAS as any stock of a corporation (i) for which, as of the date of the contribution, market quotations are readily available on an established securities market, and (ii) which is capital gain property, as defined in § 170(b)(1)(C)(iv).

Section 170(b)(1)(C)(iv) provides that for purposes of this paragraph, the term "capital gain property" means, with respect to any contribution, any capital asset the sale of which at its fair market value at the time of the contribution would have resulted in gain which would have been long-term capital gain.

Section 1222(3) provides that "long-term capital gain" means gain from the sale or exchange of a capital asset held for more than one year, if and to the extent such gain is taken into account in computing gross income.

Section 170(e)(5)(C)(i) provides that in the case of any donor, the term QAS shall not include any stock of a corporation contributed by the donor in a contribution to which § 170(e)(1)(B)(ii) applies (determined without regard to this paragraph) to the extent that the amount of the stock so contributed (when increased by the aggregate amount of all prior such contributions by the donor of stock in such corporation) exceeds 10 percent (in value) of all of the outstanding stock of such corporation. Section 170(e)(5)(C)(ii) provides that for purposes of clause (i), an individual shall be treated as making all contributions made by any member of his family (as defined in § 267(c)(4)).

Section 170(e)(5) was added to the Code by the Tax Reform Act of 1984, Pub. L. 98-369. Congress believed "that deductibility at full fair market value for gifts of appreciated stock to private nonoperating foundations should be permitted in certain situations in which the potential for abuse, including overvaluations, is minimized." H. Rep. No. 432, Part 2, 98th Cong., 2d Sess. 1464 (1984); Joint Committee on Taxation Staff, General Explanation of Revenue Provisions of the Deficit Reduction Act of 1984, 98th Cong. 667 (1984).

While § 170(e)(5) does not specify under what circumstances "market quotations are readily available on an established securities market," the Tax Court has concluded that this requirement is satisfied if the requirements under § 1.170A-13(c)(7)(xi)(A) are satisfied. See Todd v. Commissioner, 118 T.C. 334, 346 (2002).

Section 1.170A-13(c)(7)(xi)(A) provides that publicly traded securities means securities (within the meaning of § 165(g)(2)) for which, as of the date of the contribution, market quotations are readily available on an established securities market. Market quotations are readily available on an established securities market with respect to a security if the security is regularly traded in the national or regional over-the-counter market for which public quotations are available. Section 1.170A-13(c)(7)(xi)(A)(2).

Section 1.170A-13(c)(7)(xi)(C)(1) provides, in part, that securities described in § 170A-13(c)(7)(xi)(A) shall not be considered publicly traded securities if the securities are subject to any restrictions that materially affect the value of the securities to the donor or prevent the securities from being freely traded.

Securities Act and SEC Rules

Section 5 of the Securities Act provides, in part, that unless a registration statement is in effect as to a security, it shall be unlawful for any person, directly or indirectly, to sell such security to the public. 15 U.S.C. § 77e(a). Section 4(a)(1), however, provides that section 5 shall not apply to transactions by any person other than an issuer, underwriter, or dealer. 15 U.S.C. § 77d(a). SEC Rule 144 sets forth a safe harbor that, if satisfied, deems certain persons not to be "underwriters" of securities. 17 C.F.R. § 230.144(b).

SEC Rule 10b5-1 defines when a purchase or sale constitutes trading "on the basis of" material nonpublic information in insider trading cases brought under Section 10(b) of the Exchange Act and Rule 10b-5 thereunder. 17 C.F.R. § 240.10b5-1. Additionally, SEC Rule 10b5-1(c) provides a number of affirmative defenses that, if demonstrated by a person making the purchase or sale of a security, would establish that such purchase or sale was not "on the basis of" material nonpublic information when the person made the purchase or sale. 17 C.F.R. § 240.10b5-1(c). Specifically, SEC Rule 10b5-1(c)(i)(A)(3) provides, in part, that subject to paragraph (c)(1)(ii) of this section, a person's purchase or sale is not "on the basis of" material nonpublic information if the person making the purchase or sale demonstrates that before becoming aware of the information, the person had adopted a written plan for trading securities. 17 C.F.R. § 240.10b5-1(c)(1)(i)(A)(3).

SEC Rule 10b5-1(c)(1)(ii) provides, in part, that paragraph (c)(1)(i) is applicable only when the plan to purchase or sell securities was given or entered into in good faith and not as part of a plan or scheme to evade the prohibitions of this section. 17 C.F.R. § 240.10b5-1(c)(1)(ii).

SEC Rule 144(e) provides a limitation on the amount of securities sold. SEC Rule 144(e) provides that the amount of securities sold for the account of an affiliate of the issuer in reliance upon this section is generally determined as follows:

(1) If any securities are sold for the account of an affiliate of the issuer, regardless of whether those securities are restricted, the amount of securities sold, together with all sales of securities of the same class sold for the account of such person within the preceding three months, shall not exceed the greatest of:

(i) One percent of the shares or other units of the class outstanding as shown by the most recent report or statement published by the issuer, or

(ii) The average weekly reported volume of trading in such securities on all national securities exchanges and/or reported through the automated quotation system of a registered securities association during the four calendar weeks preceding the filing of notice required by paragraph (h), or if no such notice is required the date of receipt of the order to execute the transaction by the broker or the date of execution of the transaction directly with a market maker, or

(iii) The average weekly volume of trading in such securities reported pursuant to an effective transaction reporting plan or an effective national market system plan as those terms are defined in § 242.600 of this chapter during the four-week period specified in paragraph (e)(1)(ii) of this section. 17 C.F.R. § 230.144(e).

Analysis

Under § 170(e)(5)(B), the Contributed Shares are stock for which, as of the Contribution Date, market quotations are readily available on an established securities market.

Taxpayers represent that LLC held the Contributed Shares at all times as a capital asset, and that LLC 1 held the Contributed shares for more than one year. Taxpayers also represent that, as of the Contribution Date, the fair market value of the Contributed Shares exceeded their adjusted basis.

Taxpayers represent that, following LLC 1's contribution of the Contributed Shares to Private Foundation on the Contribution Date, Taxpayers, Trust 1, Trust 2, LLC 1, and LLC 2 will not have contributed in aggregate more than ten percent by value of Corporation 1 stock to Private Foundation when aggregated with prior gifts of Corporation 1 stock by such persons to any private nonoperating foundation.

Taxpayers represent that the Contributed Shares could at any time be sold in their entirety on Exchange at Exchange prices pursuant to the exemption to the registration requirement set forth in section 4(a)(1) of the Securities Act and the safe harbor set forth in SEC Rule 144.

Based on Taxpayers' representations, the fact that Taxpayers, and entities over which they exercise control, are subject to insider trading policies that require Taxpayers and such entities to conduct purchases and sales of Corporation 1 securities pursuant to an SEC Rule10b5-1 written trading plan does not subject the Contributed Shares to any restriction that materially affects the value of the Contributed Shares to Taxpayers as the donors or prevents the Contributed Shares from being freely traded.

Based on Taxpayers' representations, the SEC Rule 144(e) volume limitations do not subject the Contributed Shares to any restriction that materially affects the value of the Contributed Shares to Taxpayers as the donors or prevents the Contributed Shares from being freely traded.

RULING


Based on the information submitted and representations made by Taxpayers, we rule as follows:

Provided the requirements of § 170 are otherwise satisfied, the Contributed Shares of Stock 1 of Corporation 1 indirectly contributed by Taxpayers to Private Foundation constitute "qualified appreciated stock" within the meaning of § 170(e)(5)(B) of the Code.

CAVEATS


The rulings contained in this letter are based on facts and representations submitted by Taxpayers and accompanied by a penalty of perjury statement executed by an appropriate party. This office has not verified any of the materials submitted in support of the request for rulings. Verification of the information, representations, and other data may be required as part of the examination process.

Except as expressly provided herein, no opinion is expressed or implied concerning the tax consequences of any aspect of any transaction or item discussed or referenced in this letter.

No opinion is expressed or implied regarding whether the contribution of the Contributed Shares constitutes a "charitable contribution" within the meaning of § 170(c).

No opinion is expressed or implied regarding the tax consequences of any potential future transaction involving Corporation 1 securities.

No opinion is expressed or implied regarding the assignment of income doctrine.

No opinion is expressed or implied regarding excess business holdings within the meaning of § 4943(c).

No opinion is expressed or implied regarding private inurement within the meaning of § 501(c)(3).

No opinion is expressed or implied regarding any issues under Chapter 42 of the Code, affecting private foundations.

PROCEDURAL STATEMENTS


This ruling is directed only to the taxpayer requesting it. Section 6110(k)(3) of the Code provides that it may not be used or cited as precedent.

In accordance with the Power of Attorney on file with this office, a copy of this letter is being sent to your authorized representatives.

A copy of this letter must be attached to any income tax return to which it is relevant. Alternatively, taxpayers filing their returns electronically may satisfy this requirement by attaching a statement to their return that provides the date and control number of the letter ruling.

Sincerely,

Norma C. Rotunno
Branch Chief, Branch 1
(Income Tax & Accounting)


Published December 14, 2018
Print
Email
Subsribe to RSS Feed

Previous Articles

Foundation's Set-Aside Approved

Organization that Limited Scholarships to Family Members Loses Exemption

IRS Rules on Gift Tax Consequences of Proposed Disclaimers

CRUT Provisions Approved

Tax-Free Spousal IRA Rollover Permitted

scriptsknown

Shelby Harder, 2018
Dr. Irving Auld and Dorothy
Roher Auld Scholarship

"Many students take for granted what a university has to offer. However, I am thankful every single day for the opportunity to attend this prestigious school. At Lawrence, you have the ability to engage in Socratic debates about the world we live in at dinner, play recreational or NCAA sports, and talk one on one with brilliant professors. At Lawrence, you don't just 'learn' a subject, you are immersed in it. You dive into the liberal arts and these professors show you the beauty in it all, and how everything is tied together. I am a Biochemistry major with a soft spot for rocket science, philosophy, and evolution. Lawrence is my dream school, and it would have never been possible without the Dr. Irving Auld and Dorothy Roher Auld Scholarship. I am forever grateful for their generosity."

Juliana E. Olsen-Valdez, 2018
Carroll Family Scholarship

"Lawrence University is a great place for students looking to embrace their multi-interested approach to learning. As a Geology major, I have spent many long hours in laboratories. But, I have also had the opportunity to organize and lead students on outdoor backpacking trips, help build a stronger community for International students, participate in dialogues on campus initiatives, attend dozens of musical events, and study abroad in a field-based geology program, all while taking classes in a variety of academic spheres on campus. Lawrence, as an institution and student body, creates a collective of learners, listeners, and leaders who are continuously evolving their understanding of the world around them. I am fortunate to have the support of the Carroll Family Scholarship, so that I can say I am a part of this exceptional community too!"

Weiqi "Vicky" Liang, 2019
Marian H. Cuff Endowed Scholarship

"Lawrence is a special institution with nice people around the campus. I better myself by trying out different things and using new ways to think critically. Even though I am a Philosophy major, I have successfully taken classes in Anthropology, Biology, Economics, and Government. In addition, I still find many great extracurricular opportunities to explore, such as singing with Viking Chorale, even though I am not a music major. While having the great experience of volunteering at the elderly center last year, I became an elder advocacy coordinator at the Volunteer Community Service Center. At Lawrence, I've learned to handle difficult academic problems while looking forward to exploring possible opportunities. I am very grateful to be awarded the Marian H. Cuff Endowed Scholarship for every year I have been here, and appreciate that the scholarship has provided this wonderful Lawrence experience to me."

Anthony Cardella, 2018
Ansorge Family Scholarship

"I am so excited that I am able to attend Lawrence University. I know that I will make great progress studying piano with Dr. Michael Mizrahi. Since being at Lawrence I've already made a lot of progress and I really love it here. I am so grateful for the Ansorge Family Scholarship that made it possible for me to come to Lawrence because without it, I might not have been able to afford the cost of attending a school that is a great fit for me and a place where I will learn so much and go so far."

Milwaukee-Downer Scholarships and Professorships

Some of the many recipients of Milwaukee-Downer scholarships gather for a photo with Carolyn King Stephens M-D'62 and Marlene Crupi-Widen M-D'55 in January 2014 at the annual scholarship luncheon.

Rosamund Victoria Bille Adler Scholarship
Dr. Charles E. Albright Scholarship
Helen Daniels Bader Scholarship
James G. and Ethel M. Barber Scholarship
Catharine Beecher Endowed Fund for Downer Women
Bessie A. Bell Scholarship
Berk Scholarship
Frederick C. Best Scholarship
Beta Study Club Scholarship
Lynde Bradley Scholarship
Lucia R. Briggs-Alumnae Scholarship
Edith Lange Brooks Scholarship
Anne Barman Caldwell Scholarship
Alice Miller Chester Scholarship
City of Milwaukee Student Funds Scholarship
Milwaukee-Downer Class of 1940 Fund
Milwaukee-Downer Class of 1942 Fund
College Endowment Association Scholarship
Janet Cope Crawford Scholarship
Jessie Mabbott Daniels Scholarship
F. T. Day Scholarship
Rufus Dodge Scholarship
Julia P. Ely and Hannah R. Vedder Memorial Scholarship
General Endowed Scholarship - M-D College
Dr. Alfred W. and Mrs. Ada F. Gray Scholarship
Berenice E. Hess Scholarship Endowment
Lucille Ray Hibbard Scholarship
Belle Austin Jacobs Scholarship
Helen McDermott Jurack and Ronald J. Mason Scholarship
Marjorie S. Logan Scholarship
Nellie Maxwell Scholarship
S. Annabelle & Paul McGuire Scholarship
Memorial Scholarship Fund - Milwaukee-Downer
Milwaukee-Downer Class of 1953 Scholarship
Milwaukee-Downer Class of 1955 Scholarship
Milwaukee-Downer Class of 1956 Scholarship
Milwaukee-Downer Class of 1957 Scholarship
Milwaukee-Downer Class of 1958 and 1959 50th Reunion Scholarship
Milwaukee-Downer Club Scholarship
Milwaukee-Downer/Lawrence College Consolidation 50th Anniversary Scholarship
Francis Evelyn Kelley Morgan Memorial Scholarship
O'Neill-Anderson Family Scholarship Endowment
Elizabeth A. Olson Scholarship
Gilbert Haven Peirce, Sr. and Emma Elizabeth Manor Peirce Milwaukee-Downer Scholarship
Aleida J. Pieters Scholarship
Matilda Siefert Puelicher Scholarship
Elizabeth Ann Richardson Scholarship
William M. Ross Memorial Scholarship
Elizabeth Rossberg Scholarship
Charles Frederic Sammond Scholarship
Mildred L. Schroeder Scholarship
Sivyer Educational Fund for Women
Marion Merrill Smith Scholarship
Dr. Elizabeth A. Steffen Scholarship
W. Mead and Elizabeth McKone Stillman Scholarship
Strzelczyk Family Scholarship
Clare Scherf Sweetman Scholarship
Raymond H. and Jane K. Taylor Scholarship
Jerline E. Walfoort Memorial Scholarship
Barbara E. Wehr Fund
Harmony Weissbach Scholarship
Martha and Frances Wheelock Scholarship
James G. and Ethel M. Barber Professorship of Theatre and Drama
T. A. Chapman Professorship in Music
Alice G. Chapman Professorship in Physics
Alice G. Chapman Librarianship
Milwaukee-Downer College and College Endowment Association Professorship

Angela Small Fry Intia, 2019
Maurine Campbell Scholarship

"Thanks to the Maurine Campbell scholarship, I have been able to attend the amazing school that is Lawrence University. With the help from this scholarship, I have been able to pursue my dream career in chemistry working with the outstanding and extremely helpful faculty here. Even outside of chemistry I take the time for exploration into my interests and want to give back through my work as a resident life advisor, stock room assistant, and student supervisor at Bon Appetit. Everything I have learned here, academically or not has forever molded the person I am today."

LarryU Facebook Twitter Instagram YouTube

© Copyright 2018 Crescendo Interactive, Inc. All Rights Reserved
PRIVACY STATEMENT
This site is informational and educational in nature. It is not offering professional tax, legal, or accounting advice.
For specific advice about the effect of any planning concept on your tax or financial situation or with your estate, please consult a qualified professional advisor.