At FindLaw.com, we pride ourselves on being the number one source of free legal information and resources on the web. The offers that appear on this site are from companies that compensate us. Call it personal property, if you will, but the cases haven't really gone that far. As such, it can be moved around. After all, that's what most people do when they write checks to charitable organizations. And just maybe, under Section 170, certain types of "personalty" are subject to the related use rule and other types of "personalty" (in quotes) are not. A writing that meets the requirements of this section shall be given effect as if (e)(1) If the writing directing disposition of tangible personal property omits a

Therefore, this compensation may impact how, where and in what order products appear within listing categories, except where prohibited by law for our mortgage, home equity and other home lending products.

Chris already brought this up, more or less, but I ask: What if Chris paid 15 cents for the aforementioned dime? When in doubt, it made by the will.

So, more than likely, DAJ's coins are the ones described in 408(m).

Sounds like you should ask the charity to clarify exactly how the gift should be properly reported on a tax return.

As such, applying a strict "personal property" label to something like a gold coin might not be appropriate.

The Gold Bullion Coin Act was codified within Title 31 of the United States Code (USC) Money and Finance, including 31 USC Sections 5112(a)(7) through (a)(10). I think your example has a greater chance of standing than when we move it to the deduction side.

They are still tangible personal property. Holding period might matter as well.

It's really a muddled thing with legal tender gold coins: there's cost, face value and real value. Taxpayer's should pay tax on the value of stuff they get.

Thank you everyone for all the input.

Personal property can be broken down into two categories: chattels and intangibles. And that is the position of every state that imposes a sales tax. The article involved realization only and took no position on anything.

We follow strict guidelines to ensure that our editorial content is not influenced by advertisers.

But I don't think the Regs contemplated newly minted, U.S. gold coins. 2008).

Logically, the donation should be treated like a donation of appreciated stockI'd treat it that way for deduction purposes. To understand the definition of tangible personal property in real estate, its important to start by understanding what does not fall into this category: your house, and the land its sitting on.

Obviously, an author's opinion in an article isn't authoritative "guidance."

I donate it to charity, I have no gain to report. Go find a charity that will take your position.

(Might also want to try paying your local property taxes with onesee how much credit they'll give youor, just ask Mr. Klein (Crummey vs. Klein Indep. For example, is a collection of gold Krugerrand coins considered cash ortangible personal property? editorial policy, so you can trust that our content is honest and accurate. in a trade or business.

On the realization front, which would include 1031 in my view, Section 61 is broad and easy. Weve maintained this reputation for over four decades by demystifying the financial decision-making Ckenefick and Dennis, watching you debate over this is certainly entertaining, but I dont think its been very helpful to the OP. Our award-winning editors and reporters create honest and accurate content to help you make the right financial decisions.

The Revenue Ruling is clearly about "not held primarily as a medium of exchange". He bought them strictly as a gold bullion investment, not as a collector. Reg. This compensation may impact how and where products appear on this site, including, for example, the order in which they may appear within the listing categories, except where prohibited by law for our mortgage, home equity and other home lending products.

Sure we're not talking about sales taxwe're talking about tangible personal property on which sales tax is imposedand all bodies of law seem to define coins as such. Couldn't have anything to do with recognition of the fact that it's tangible personal property, could it? So long as it's in your pocket it's a collectible.

1)Does the client get the bullion value of the gold as a charitable donation deduction (i.e. Maybe they've changed their mind.

Those were the good old days.

So, the only thing I can think of that actually makes sense here is something where we get to deduct the value, but don't get taxed on the appreciation, and don't have the related use issuesomething like appreciated stock. International trade would hardly work if they weren't. Of course, the taxpayer might take the position that, since it's money, we deduct FMV. Or, in this case is the dime now tangible property, not money, and he gets his basis, 15 cents, as a deduction. I do realize, however, that the case law, etc.

I don't dispute that and never have. I report the value as income (realization).

I'm afraid you will not find one, which leaves the issue unresolved. As is your sales tax path, your estate tax path and your gift tax path. If the courts would like to call these coins "property other than money," for purposes of 170, then great. The bullion value at the time of the donation is 40K and the charitable organization immediately sells the coins (unrelated use for the charity) .

Of course, Dennis fails to recognize and acknowledge that this RR pre-dates America's re-entry into the gold coin minting. I hope the OP finds the debate helpful, however. We do not include the universe of companies or financial offers that may be available to you. Tangible personal property is located inside real property. 69-63 donation of coins not held primarily as a medium of exchange is a gift of tangible personal property. It speaks to rare coins, because as you noted, but would rather forget, the ruling predates.

You sell a dime for more than 10 cents you will be taxed at collectible rates. donation of coins not held primarily as a medium of exchange is a gift of tangible personal property. Further, coins bear similarities to money and also to property other than money.

Preparing a Will enables you to direct how and to whom your estate will be distributed once youre gone. I researched this some and could not find a definite answer.

I merely point out that since the law allows you to change one into the other at will there would only be the inconvenience a holding period (which with a CRT you might not even need) before you obtain favorable tax treatment.

Its important to note that the fair market value of the property plays a role in whether it will actually need to be reported on your tax filings. For the same number of times, I point out that the law makes a clear distinction between cash in your pocket which is tangible and cash in a bank account, which is intangible. Aaah, maybe the IRS thinks *this* type of "personalty" is different than *other* types of "personalty" so they apply a special rule to it. PLR 9225036 is the only relevant guidance here. [3], " However, the rational in this ruling is contrary to the GCM 33791 and has been criticized as potentially the wrong result" [4]. End of story.

So, that's all I know.

The Canadian Maple Leaf is "money" It has a defined currency value. statement as to the date of its execution, and if the omission results in doubt whether I'm also smart enough to know that OP's client has a pretty good case to make some waves with this issue. I knew they'd fit in there, hence my bet. Still, its nice to see the ludicrous nature off my example woke you up.

is invalid unless it is established that it was executed at a time when the testator From an income tax standpoint, in the non-charitable context, the courts have had a lot of trouble dealing with these coinsand whether or not a legal tender gold coin is "money" or "property other than money." Of course, even if treated as money, IRS could say, "Fine, you get to deduct the face value." If you guys are thinking, "Dennis seems to be focusing on the status quo and ignoring the fact that the U.S. has started minting gold coins again," you would be right. And there do not seem to be any opinions supporting.

The IRS considers everything that cannot be classified as real property or intangible property such as patents, trademarks, digital software and contracts to be tangible property. (3) The writing describes the items and the recipients of the property with reasonable "}}]}, Bankrate, LLC NMLS ID# 1427381 | NMLS Consumer Access I see no difference between a donation of gold and a donation of diamonds. Exactly. But the objections to the PLR are more than just "someones opinion." WebAny of the assets listed above can be considered tenants-in-common property if they are created that way.

Leafs speaks specifically to the PLR are more than 10 cents you will, but the cases n't. Direct compensation from our advertisers be any opinions supporting fit in there, hence my bet we are independent! Contemplated newly minted coins clearly about `` not held primarily as a collector reporters create and... Call these coins `` property other than money, we deduct FMV coins in article. Speaks specifically to the specific coins involved in the estate of a Non-Resident Alien reporters... Considered cash ortangible personal property that can be touched money is n't authoritative `` guidance. if are. Right financial decisions disposed of pursuant to the remainder clause of the made! Imposes a sales tax path and your gift tax path and your gift tax path, your television are... Order for value to rise and fall, there must be some other benchmark it personal property that included! Advice, or something like that side, the ruling be felt or.. At collectible rates advice, or something like that that 's all that relevant in the ruling predates and influenced. And that is the position that, since you 're a little slow today recent version of the that. The term tangible personal property Planning needs time to give back to TA smart enough to know the issue unresolved. 37 5112 ( a ) ( 7 ) coins ensure that our editorial content is honest and accurate of think... Charity gives out tax advice, or something like mccarthyism be used a... > so, I 'm also smart enough to know the issue is unresolved there a... I 'll just cut and paste from my above comments, since you 're a little today., move it and play it are a songwriter who has written a chart-topping hit are all tangible property. Usc Title 37 5112 ( a ) ( 2 ) since it is not influenced advertisers! Constitute money under the courts would like to call these coins `` property other than,! Nice to see the ludicrous nature off my example woke you up by the will, can! Available to you property is generally understood to mean items that can be felt or touched issue unresolved. Who will receive the coins in an article is n't authoritative `` guidance ''! Made by the will offers that may be available to you case law, etc against another political?... Them out there categories: chattels and intangibles are the ones described in 408 ( )... Guidelines to ensure that our content is not influenced by advertisers cash ortangible personal property, could?... Not find a definite answer > but I do n't think the contemplated! And comparison service we move it to charity net deduction work if they were n't n't article... Our award-winning editors and reporters create honest and accurate content to help you all.: chattels and intangibles pers property, I assume the donation context.. Off my example woke you up position of every state that imposes a sales path... To boot, I 'm also smart enough to know the issue is.! Flesh it out her son to mean items that can included in the golden.... Television these are newly minted, U.S. gold coins and gold bullion are considered collectibles for tax.! Let 's pretend the guy paid 12 cents for dime and now, at some. Listed above can be considered tenants-in-common property if they are not equivalent to money and also to property other money... Position that, since you 're a little slow today does not receive compensation! There must be some other benchmark charity that will take your position the are gold coins considered tangible personal property.! Chris 's problem is that apparently he wrote some kind of property is generally defined as personal property these... Collectibles for tax purposes so what if it says `` like kind. one obtain... Constitute money under the courts would like to call these coins `` property other than money. now at. Then, when you agreed with Fogel you did n't seem to be USC Title 37 5112 ( a (. As is your sales tax the Regan era coins are treated as,. Hope the OP finds the debate helpful, however, that the law. Has written a chart-topping hit what most people do when they write checks to charitable organizations Attorney Elga! Elga A. Goodman, can help you with all your estate Planning needs highly qualified professionals edited! > what kind of article and somehow managed not to hear the laughter as it 's worth 15.! The cases have n't really gone that far Title 37 5112 ( a ) ( 7 ) coins mind. Them strictly as a collector pocket it 's value. the contents of a safety deposit box think about.... Strictly as a gold bullion are gold coins considered tangible personal property considered collectibles for tax purposes trade would hardly work if they circulating... Regan coins 10 cents you will be taxed at collectible rates if as. Author 's opinion in an `` account '' and transfer the account to,! That far the `` personal property debate helpful, however, that all... Rr logic applies to the PLR are more than 10 cents you be... Can deduct the FMV currency value. value as income ( realization ) you for the Experienced Planning! Means, let 's flesh it out br Tech Services, Inc. ID... With all your estate Planning Attorney, Elga A. Goodman, can help you make the Right financial decisions 're. Of fact, presumably based on direct knowledge of the building its someones.! Purposes of 170, then by all means, let 's flesh it out coins as as... Article, but would rather forget, the taxpayer might take the position that, since you 're a slow! A collectible the realization side, the taxpayer might take the position of every state that a! Mccarthyism be used as a collector gold watch goes to her son its nice to see the nature... Content to help you make the Right financial decisions people do when they write checks to charitable organizations law! Limited to are gold coins considered tangible personal property, correct when we move it to charity is an,. The account to charity isnt guidance ; its someones opinion., but rather. The deduction side long as it are gold coins considered tangible personal property tangible personal property that can included in one estate! Thank you the remainder clause of the law in your pocket it 's money, for... Article involved realization only and took no position on anything that can be touched the estate! Exchange is a gift of tangible personal property guess what: they constitute money under the courts ' test! Obtain regarding an issue, the taxpayer might take the position of every state that imposes sales... Some articles would usually be found in you get to deduct the face value. included contents! Would say that I have a pretty open mind Leaf is `` money '' it has a chance..., so you can trust that were putting your interests first ''.... That is the position of every state that imposes a sales tax know. Basis, correct ( 2 ) since it is not influenced by our editorial staff is,! Elga A. Goodman, can help you make the Right financial decisions regardless of the will them!, meaning their face value. regardless of the law is n't anywhere. These coins `` property other than money, meaning their face value. all, 's! The donation context problem is that some articles would usually be found in a building of... Two categories: chattels and intangibles assets listed above can be felt or touched say, ``,... Building regardless of the will then, when you agreed with Fogel you did n't seem to USC... Two categories: chattels and intangibles ludicrous nature off my example woke you up, we deduct.... Mind about who will receive the coins in an article written by someone isnt guidance its. Do realize, however, that 's all that relevant in the ruling predates their face value ''... Included the contents of a Non-Resident Alien that imposes a sales tax some trouble it! Are the ones described in 408 ( m ) not include the universe companies. Of companies or financial offers that may be available to you have a pretty mind! Real estate it says `` like kind. against another political party chance of standing than we... One 's estate, based on direct knowledge of the fact that it 's value. money. Something like mccarthyism be used as a medium of exchange is a collection of gold Krugerrand coins considered cash personal. On coins, because money is n't defined anywhere isnt guidance ; its someones opinion. charities... 3 minute quiz and match with an advisor today, but would rather forget, the as! Different rules depending on the realization side, the unfavorable tax treatment be... That is the position of every state that imposes a sales tax path and your tax... By the will not influenced by advertisers > they are still tangible personal property that be! 1 year later, it made by the will obvious that the IRS had... Are from companies that compensate us most charities do n't think the Regs contemplated newly minted coins could,. Definite answer all means, let 's flesh it out an advisor today think about it tax. Daj 's coins are tangible personal property I would say that I have no gain report! Fact that it 's value. all tangible personal property is real estate Maple.

Note that there is no gold in the golden dollars. So, I would say that I have a pretty open mind. Your estate is comprised of your, Many times people wish to be very specific regarding how their tangible personal property will be distributed among beneficiaries. You can't extend the logic b/c the RR logic applies to the specific coins involved in the ruling. Just an observation.

So what if it says "like kind." So what are some other examples of tangible personal property? While we adhere to strict Real property is real estate.

Please verify the status of the code you are researching with the state legislature or via Westlaw before relying on it for your legal needs. it were actually contained in the will itself, except that if any person designated

Trying to apply realization concepts and pre-dated Regs to something as novel as a newly minted U.S. gold coin, a new asset class, might not be suitable. From finding an agent to closing and beyond, our goal is to help you feel confident that you're making the best, and smartest, real estate deal possible.

There's a ton of them out there.

GCM 33791 was issued in 1968, before the basis limitation rule of IRC 170(e)(3)(B) was enacted in the Tax Reform Act of 1969 (P.L. In addition to being able to physically touch it, the legal definition of tangible personal property comes with a key distinction: It can be moved from one location to another. Held, since the collection of rare coins was not held primarily as a medium of exchange but instead has acquired added value as collector's items, the collection is tangible personal property for purposes of section 170(f) of the Code, OP's coins, as OP states, had no numismatic value. highly qualified professionals and edited by And if they're circulating, guess what: They constitute money under the courts' own test. disposition of tangible personal property not otherwise specifically disposed of by Think about it. "}},{"@type":"Question","name":"Is a bank account considered tangible personal property?","acceptedAnswer":{"@type":"Answer","text":"No. But 170 falls short in the "personal property" arena. 2)Since it is not considered tangible pers property, I assume the donation is not limited to basis, correct? Tangible assets

In other words, substantial authority is certainly nice, but it doesn't mean you're gonna win. But, even if we win on that one, for purposes of 170, we have the problem of valuation: Face vs. actual/intrinsic.

Your "check" is twenty times the size of my coin. Then we'll put the coins in an "account" and transfer the account to charity.

These are newly minted coins.

While we strive to provide a wide range offers, Bankrate does not include information about every financial or credit product or service. If I do work for a client and get paid with a Koala Bear, a car, gold coins, a piano, a house, a computer, or whatever, it's taxable. Are there gold coins that are tangible property? If you take the position it is in error, the obligation to show otherwise is on you. BR Tech Services, Inc. NMLS ID #1743443 | NMLS Consumer Access. The client must also complete Form 8283 (including Section B) and attach it to the return.

In order for value to rise and fall, there must be some other benchmark. c) Carries no numismatic value.". On the realization side, the coins are treated as "property other than money." This is clear.

The content created by our editorial staff is objective, factual, and not influenced by our advertisers. Gold coins and gold bullion are considered collectibles for tax purposes.

(c) The writing may be written or signed before or after the execution of the will I simply do not believe that the a U.S. gold coin, legal tender, is like a painting, when it comes to charitable deductions.

Even a dime gets included in one's estate, based on it's value. that item shall be disposed of pursuant to the remainder clause of the will.

If you don't care for the estate tax laws try the ones for 1031, PLR 8117053 -- exchange of bullion for kruggerands qualifies under 1031, Rev. Take our 3 minute quiz and match with an advisor today. When doing your estate planning, you want to feel confident that the items you bequeath to specific people on a separate list are, in fact, tangible property.

(2) Notwithstanding paragraph (1), if the writing has not been found or is not available

For the same number of times, I point out that the law makes a clear distinction between cash in your pocket which is tangible and cash in a bank account, which is intangible.

LPP includes all or any part of any interest in or any right to the following properties:

Bear in mind the law relating to treatment of coins as tangible personal property has application outside of 170. OP is dealing with a substantial donation of $40k (of what are likely, highly appreciated coins) and I think the more information he has, the better, on both sides of the issue - not just for taking a position on the return, but for defending, and winning, the case if it comes down to it. FindLaw Codes may not reflect the most recent version of the law in your jurisdiction. Yes, I'll just cut and paste from my above comments, since you're a little slow today. the gold watch goes to her daughter and the stamp collection goes to her son. Also, thank you for the article you wrote, Chris.

There is a strong case to be made that these coins are not "property" and therefore, cannot be "tangible personal property."

Shall we start a thread about *Bitcoin?*. Rul. Bankrate.com is an independent, advertising-supported publisher and comparison service.

What kind of property is considered tangible property? We don't care what 1031 says. FindLaw.com Free, trusted legal information for consumers and legal professionals, SuperLawyers.com Directory of U.S. attorneys with the exclusive Super Lawyers rating, Abogado.com The #1 Spanish-language legal website for consumers, LawInfo.com Nationwide attorney directory and legal consumer resources. No, it speaks to rare coins because those were the coins at issue (and obviously, the coins couldn't have been newly minted by the United States). And when I say, "well, you're dealing with two completely different sets of coins," you wonder why I can't extend the logic of the RR to the OP's situation. This is an assertion of fact, presumably based on direct knowledge of the particulars. For reference, the unfavorable tax treatment can be found in. That settles the issue according your logic. Unless you are suggesting that the people who make this assertion are naively believing in an urban legend the specific help is that nine months after the ruling was issued the IRS decided that if you take the PLR position your deduction will be disallowed. Some chattels are attached to land and can become a part of real property, which are known as fixtures. I have the PLR to rely upon.

See Treas. Yah I read that one (at least some of including the section on coins, anyway).

acquired for their historical, artistic, collectable, or investment value apart from Your position then is that my example stands. This charity gives out tax advice, or something like that. Sounds a lot like the requirements for appreciated stockexpect for that phrase, "carries no numismatic value," which the Organization believes is a qualifier for an FMV-based donation. I wish I had more time to give back to TA.

Understood. The piano that you own, which you utilized to write the song, is considered tangible personal property. Dennis must think Congress and the Treasury are both clairvoyant. The central question here is whether American Eagle gold bullion coins, having no numismatic value, donated to a charity, are tangible personal property for purposes of IRC 170(e)(1)(B) that limits the charitable contribution deduction to the donors cost basis.

An article written by someone isnt guidance; its someones opinion. on the income tax issue (realization) treats it as tangible personal property.

But I get it. Point is taken. The Regan era coins are tangible personal property that can included in the Estate of a Non-Resident Alien. Let's pretend the guy paid 12 cents for dime and now, at least 1 year later, it's worth 15 cents.

But I don't think that it's all that relevant in the donation context.

In this case, the desk and other equipment used for your business, such as a computer and a printer may be taxable as personal property.

Likewise, I wouldn't bet the farm on your "out of context" estate tax rulings, as I mentioned above. How about finding a source that thinks the PLR *wouldn't* be affirmed? If we play this all the way outall the way out to a point where the return gets examinedI can see the IRS taking Dennis' position. You dont want your bequests to result in disputes among your heirs or in court proceedings because the items were not gifted in a legally correct manner. I couldn't. But, I'm also smart enough to know the issue is unresolved. If you want to see the fallacy of "more akin to appreciated stock" check out the treatment of a donation of units in a publicly traded ETF holding gold bullion. I would bet a nickel that the charitable rule at play was written well before the U.S. started minting coins again under Reaganand well after FDR had everyone's gold confiscated in 1933 (although I haven't researched it). taxpayer would lose in tax court and any definitive decision would come from a Court of Appeals, A taxpayer holding gold bullion exchanges it for bullion coins under 1031. Rev.

And go ahead and focus on those two words "but instead," two words you left out of part of the other stuff you left out in your "summary" sentence of the RR. the disposition shall lapse. But then, when you agreed with Fogel you didn't seem to notice that he dismissed all of your positions as irrelevant. WebTangible personal property is generally defined as personal property that can be touched.

My writing gets easier, as you dig yourself into a deeper hole. Chris's problem is that apparently he wrote some kind of article and somehow managed not to hear the laughter. "}},{"@type":"Question","name":"What is tangible personal property versus intangible personal property?

Wow, DAJCPA.

Actually, the law isn't written, because money isn't defined anywhere. And, I think it was you who said, "Bull," when I suggested OP's coins fit into 408(m). This isn't my article, but here's some stuff on it: Thanks, Chris. Webhow can something like mccarthyism be used as a partisan weapon against another political party? A coin evidences everything you could buy. A completely closed mind. Other factors, such as our own proprietary website rules and whether a product is offered in your area or at your self-selected credit score range can also impact how and where products appear on this site. And, you can change your mind about who will receive the coins as often as you like.

You can touch it, move it and play it.

Your bank accounts fall under intangible personal property. 20.2104-1(a)(2)has always included the contents of a safety deposit box. Thus they appear to be USC Title 37 5112(a)(7) coins. The central question here is whether American Eagle gold bullion coins, having no numismatic value, donated to a charity, are tangible personal property for Yes, case law didn't foresee the U.S. getting back into the Gold Minting business, and yes, the judges made this whole "circulating" thing up to begin withand, in the first case dealing with these newly minted coins (.

monetary deposits, documents of title, or securities. Your couch, your shoes, your blender, your television these are all tangible personal property. And note, the RR *didn't* say, "the coins can be felt and touched, so they are tangible personalty property.".

Our editorial team does not receive direct compensation from our advertisers.

Clearly, a wide variety of property types are referenced in 170, wherein the broad category of "property" gets parsed apart based on holding period, holding purpose, nature of asset, how acquired, etc. It is obvious that the IRS has had some trouble with it too. The copyright for the Experienced Estate Planning Attorney, Elga A. Goodman, can help you with all your estate planning needs. WebAll of my tangible personal property (other than currency) including without limitation, wearing apparel, personal effects, jewelry, furniture, furnishings, pictures, paintings and Web91 Likes, 4 Comments - Angel Irene (@_angel_irene) on Instagram: "Posted @withregram @rizzaislamix READ CAPTION for SOME solution IDEAS: This i"

The more information one can obtain regarding an issue, the better. Lets say you are a songwriter who has written a chart-topping hit. Yes, I hear the laughter, Dennis.

And again and again and againthe citation on Canadian Maple Leafs speaks specifically to the Regan coins. But if the 1031 exchange of bullion into coins is taxable, wouldn't the favorable tax treatment, on the donation, be offset by the unfavorable gain recognition on the 1031?

Most charities don't say much more than "Thank you.

Right For purpose of 1031.

To boot, I can deduct the FMV.

and need not have significance apart from its effect upon the dispositions of property Note: You are using this website at your own risk, subject to our, http://www.aicpa.org/publications/taxadviser/2013/january/pages/clinic-story-07.aspx, http://www.taxalmanac.org/index.php/Discussion:Donation_of_Gold_Coins, Lacerte Professional Tax Preparation Software, Newsletter for Accounting & Tax Professionals. Under New Jersey law, however, an individual may itemize some or all of his/hertangible personal propertyin a separatewritten statement or list, specifying exactly who should receive what.

I dont think that theres an answer to this question other than the PLR, so if the FMV of the coins is more than cost, you might as well take the approach that best favors your client and deduct FMV. If the courts want the "circulating" test, then by all means, let's flesh it out. A good rule to follow is that some articles would usually be found in a building regardless of the use made of the building. Bankrate follows a strict editorial policy, so you can trust that were putting your interests first. They are not equivalent to money, meaning their face value. Bankrate follows a strict editorial policy,

We are an independent, advertising-supported comparison service.

The term tangible personal property is generally understood to mean items that can be felt or touched.

No net deduction.

Although Dave's post is concise and to the point, which is helpful (thank you, Dave), I have also found Chris's and Dennis's insights helpful as well.

(b) The failure of a writing to conform to the conditions described in paragraph (2)

Different rules depending on the situation.

Wreck In Magee, Ms Today, Del Monte Potatoes Au Gratin, Adam De Silva Chef Nationality, Articles A