Bill Text: NY A05683 | 2017-2018 | General Assembly | Introduced
Bill Title: Relates to excise tax on telecommunication services (Part A); relates to temporary municipal assistance sales and compensating use taxes for cities of one million or more on telecommunication services (Part B).
Spectrum: Partisan Bill (Republican 11-0)
Status: (Introduced - Dead) 2018-06-14 - held for consideration in ways and means [A05683 Detail]
Download: New_York-2017-A05683-Introduced.html
STATE OF NEW YORK ________________________________________________________________________ 5683 2017-2018 Regular Sessions IN ASSEMBLY February 14, 2017 ___________ Introduced by M. of A. KOLB, OAKS, LUPINACCI, MONTESANO, RAIA, GRAF, BLANKENBUSH, McLAUGHLIN, GIGLIO, DiPIETRO -- Multi-Sponsored by -- M. of A. CROUCH, HAWLEY -- read once and referred to the Committee on Ways and Means AN ACT to amend the tax law, in relation to excise tax on telecommuni- cations services (Part A); and to amend the tax law, in relation to temporary municipal assistance sales and compensating use taxes for cities of one million or more on telecommunications services (Part B) The People of the State of New York, represented in Senate and Assem- bly, do enact as follows: 1 Section 1. This act enacts into law components of legislation relating 2 to the "mobile tax freedom act". Each component is wholly contained 3 within a Part identified as Parts A through B. The effective date for 4 each particular provision contained within such Part is set forth in the 5 last section of such Part. Any provision in any section contained within 6 a Part, including the effective date of the Part, which makes a refer- 7 ence to a section "of this act", when used in connection with that 8 particular component, shall be deemed to mean and refer to the corre- 9 sponding section of the Part in which it is found. Section three of this 10 act sets forth the general effective date of this act. 11 PART A 12 Section 1. Subdivision (cc) of section 1115 of the tax law, as added 13 by section 11 of part S of chapter 85 of the laws of 2002, is amended to 14 read as follows: 15 (cc) Notwithstanding any other provision of law to the contrary, 16 receipts from the sale of mobile telecommunications service [by a home17service provider] shall be exempt from the taxes imposed by subparagraph 18 (B) of paragraph one and paragraph two of subdivision (b) of section 19 eleven hundred five of this article [if the mobile telecommunications20customer's place of primary use is within a taxing jurisdiction outside21this state]. EXPLANATION--Matter in italics (underscored) is new; matter in brackets [] is old law to be omitted. LBD03459-01-7A. 5683 2 1 § 2. Paragraphs (a) and (h) of subdivision 1 and paragraph (a) of 2 subdivision 2 of section 186-e of the tax law, paragraph (a) of subdivi- 3 sion 1 as amended by section 2 and paragraph (h) of subdivision 1 as 4 added by section 3 of part S of chapter 85 of the laws of 2002, and 5 paragraph (a) of subdivision 2 as amended by section 2 of part P of 6 chapter 59 of the laws of 2015, are amended to read as follows: 7 (a) [(1)] "Gross receipt" means the amount received in or by reason of 8 any sale, conditional or otherwise, of telecommunication services or in 9 or by reason of the furnishing of telecommunication services. [Gross10receipt from the sale of mobile telecommunications service provided by a11home service provider shall include "charges for mobile telecommuni-12cations service" as described in paragraph one of subdivision (l) of13section eleven hundred eleven of this chapter, regardless of where the14mobile telecommunications service originates, terminates or passes15through.] Gross receipt is expressed in money, whether paid in cash, 16 credit or property of any kind or nature, and shall be determined with- 17 out any deduction therefrom on account of the cost of the service sold 18 or the cost of materials, labor or services used or other costs, inter- 19 est or discount paid, or any other expenses whatsoever except that there 20 shall, however, be allowed a deduction for bad debts with respect to 21 charges previously subjected to the tax hereunder when the debt has 22 become worthless in accordance with generally accepted accounting prin- 23 ciples consistently applied by the taxpayer. "Amount received" for the 24 purpose of the definition of gross receipt, as the term gross receipt is 25 used throughout this article, means the amount charged for the provision 26 of a telecommunication service. 27 [(2) (A) Any charge for a service or property billed by or for a28mobile telecommunications customer's home service provider shall be29deemed to be provided by such mobile telecommunications customer's home30service provider.31(B) Charges for mobile telecommunications service that are provided or32deemed to be provided by a mobile telecommunications customer's home33service provider shall be sourced to the taxing jurisdiction where the34mobile telecommunications customer's place of primary use is located,35regardless of where the mobile telecommunications service originates,36terminates or passes through.] 37 [(h) For the purpose of applying the provisions of this section to38mobile telecommunications service, the following terms when used in39relation to mobile telecommunications service shall be defined as such40terms are defined in section eleven hundred one of this chapter: "mobile41telecommunications service," "mobile telecommunications customer," "home42service provider," "licensed service area," "reseller," "serving carri-43er," "place of primary use" and "taxing jurisdiction".] 44 (a) [(1)] There is hereby imposed an excise tax on the sale of tele- 45 communication services[, except for the sale of mobile telecommunication46services that are subject to tax under subparagraph two of this para-47graph, by any person which is a provider of telecommunication services,] 48 to be paid by such person, at the rate of three and one-half percent 49 prior to October first, nineteen hundred ninety-eight, three and one- 50 quarter percent from October first, nineteen hundred ninety-eight 51 through December thirty-first, nineteen hundred ninety-nine, and two and 52 one-half percent on and after January first, two thousand of gross 53 receipt from: (i) any intrastate telecommunication services; (ii) any 54 interstate and international telecommunication services (other than 55 interstate and international private telecommunication services) which 56 originate or terminate in this state and which telecommunicationA. 5683 3 1 services are charged to a service address in this state, regardless of 2 where the amounts charged for such services are billed or ultimately 3 paid; and (iii) interstate and international private telecommunication 4 services, the gross receipt to which the tax shall apply shall be deter- 5 mined as prescribed in subdivision three of this section. 6 [(2) There is hereby imposed an excise tax on the sale of mobile tele-7communication services, by any person which is a provider of telecommu-8nication services, to be paid by such person, at the rate of two and9nine-tenths percent on and after May first, two thousand fifteen of10gross receipts from any mobile telecommunications service provided by a11home service provider where the mobile telecommunications customer's12place of primary use is within this state.] 13 § 3. Paragraph (b) of subdivision 2 of section 186-e of the tax law is 14 amended by adding a new subparagraph 5 to read as follows: 15 (5) Mobile telecommunications exclusion. The sale of mobile telecommu- 16 nication service shall in no event constitute a telecommunications 17 service, and the receipts from the sale of such service are without the 18 scope of the tax imposed by this section. 19 § 4. Paragraph (b) of subdivision 1 of section 186-c of the tax law, 20 as amended by section 1 of part P of chapter 59 of the laws of 2015, is 21 amended to read as follows: 22 (b) [(1)] In addition to the surcharge imposed by paragraph (a) of 23 this subdivision, there is hereby imposed a surcharge on the gross 24 receipts from telecommunication services[, except for the gross receipts25from mobile telecommunication services that are subject to tax under26subparagraph two of this paragraph,] relating to the metropolitan commu- 27 ter transportation district at the rate of seventeen percent of the 28 state tax rate under section one hundred eighty-six-e of this article. 29 All the definitions and other provisions of section one hundred eighty- 30 six-e of this article shall apply to the tax imposed by this subpara- 31 graph with such modification and limitation as may be necessary (includ- 32 ing substituting the words "metropolitan commuter transportation 33 district" for "state" where appropriate) in order to adapt the language 34 of such section one hundred eighty-six-e of this article to the 35 surcharge imposed by this subparagraph within such metropolitan commuter 36 transportation district so as to include (i) any intra-district telecom- 37 munication services, (ii) any inter-district telecommunication services 38 which originate or terminate in such district and are charged to a 39 service address therein regardless of where the amounts charged for such 40 services are billed or ultimately paid, and (iii) as apportioned to such 41 district, private telecommunication services. Provided however, such tax 42 surcharge shall be calculated as if the tax imposed under section one 43 hundred eighty-six-e of this article were imposed at a rate of three and 44 one-half percent. 45 [(2) In addition to the surcharge imposed by paragraph (a) of this46subdivision, there is hereby imposed a surcharge on the gross receipts47from mobile telecommunication services relating to the metropolitan48commuter transportation district at the rate of seven-tenths and two-49hundredths and one-thousandth percent on and after May first, two thou-50sand fifteen. All the definitions and other provisions of section one51hundred eighty-six-e of this article shall apply to the tax imposed by52this subparagraph with such modification and limitation as may be neces-53sary (including substituting the words "metropolitan commuter transpor-54tation district" for "state" where appropriate) in order to adapt the55language of such section one hundred eighty-six-e of this article to the56surcharge imposed by this subparagraph within such metropolitan commuterA. 5683 4 1transportation district so as to include any mobile telecommunications2service provided by a home service provider where the mobile telecommu-3nications customer's place of primary use is within such metropolitan4commuter transportation district.] 5 § 5. This act shall take effect on the first day of the sales tax 6 quarterly period, as described in subdivision (b) of section 1136 of the 7 tax law, beginning at least ninety days after the date this act shall 8 have become a law and shall apply in accordance with the applicable 9 transitional provisions of sections 1106 and 1217 of the tax law. 10 PART B 11 Section 1. Subdivision (b) of section 1107 of the tax law is amended 12 by adding a new clause 12 to read as follows: 13 (12) Except as otherwise provided by law, the exemption provided in 14 subdivision (cc) of section eleven hundred fifteen of this article 15 relating to mobile telecommunication services shall be applicable pursu- 16 ant to a local law, ordinance or resolution adopted by a city subject to 17 the provisions of this section. Such city is empowered to adopt or 18 repeal such a local law, ordinance or resolution. Such adoption or 19 repeal shall also be deemed to amend any local law, ordinance or resol- 20 ution enacted by such a city imposing taxes pursuant to the authority of 21 subdivision (a) of section twelve hundred ten of this chapter. 22 § 2. Paragraph 1 of subdivision (a) of section 1210 of the tax law, as 23 amended by section 2 of part WW of chapter 60 of the laws of 2016, is 24 amended to read as follows: 25 (1) Either, all of the taxes described in article twenty-eight of this 26 chapter, at the same uniform rate, as to which taxes all provisions of 27 the local laws, ordinances or resolutions imposing such taxes shall be 28 identical, except as to rate and except as otherwise provided, with the 29 corresponding provisions in such article twenty-eight, including the 30 definition and exemption provisions of such article, so far as the 31 provisions of such article twenty-eight can be made applicable to the 32 taxes imposed by such city or county and with such limitations and 33 special provisions as are set forth in this article. The taxes author- 34 ized under this subdivision may not be imposed by a city or county 35 unless the local law, ordinance or resolution imposes such taxes so as 36 to include all portions and all types of receipts, charges or rents, 37 subject to state tax under sections eleven hundred five and eleven 38 hundred ten of this chapter, except as otherwise provided. (i) Any local 39 law, ordinance or resolution enacted by any city of less than one 40 million or by any county or school district, imposing the taxes author- 41 ized by this subdivision, shall, notwithstanding any provision of law to 42 the contrary, exclude from the operation of such local taxes all sales 43 of tangible personal property for use or consumption directly and 44 predominantly in the production of tangible personal property, gas, 45 electricity, refrigeration or steam, for sale, by manufacturing, proc- 46 essing, generating, assembly, refining, mining or extracting; and all 47 sales of tangible personal property for use or consumption predominantly 48 either in the production of tangible personal property, for sale, by 49 farming or in a commercial horse boarding operation, or in both; and, 50 unless such city, county or school district elects otherwise, shall omit 51 the provision for credit or refund contained in clause six of subdivi- 52 sion (a) or subdivision (d) of section eleven hundred nineteen of this 53 chapter. (ii) Any local law, ordinance or resolution enacted by any 54 city, county or school district, imposing the taxes authorized by thisA. 5683 5 1 subdivision, shall omit the residential solar energy systems equipment 2 and electricity exemption provided for in subdivision (ee), the commer- 3 cial solar energy systems equipment and electricity exemption provided 4 for in subdivision (ii), the commercial fuel cell electricity generating 5 systems equipment and electricity generated by such equipment exemption 6 provided for in subdivision (kk) and the clothing and footwear exemption 7 provided for in paragraph thirty of subdivision (a) of section eleven 8 hundred fifteen of this chapter, unless such city, county or school 9 district elects otherwise as to such residential solar energy systems 10 equipment and electricity exemption, such commercial solar energy 11 systems equipment and electricity exemption, commercial fuel cell elec- 12 tricity generating systems equipment and electricity generated by such 13 equipment exemption or such clothing and footwear exemption. Any local 14 law, ordinance or resolution enacted by any city, county or school 15 district, imposing the taxes authorized by this subdivision, shall omit 16 the mobile telecommunication services exemption provided for in subdivi- 17 sion (cc) of section eleven hundred fifteen of this chapter, unless such 18 city, county or school district elects otherwise; provided that if such 19 a city having a population of one million or more enacts the resolution 20 described in subdivision (p) of this section or repeals such resolution, 21 such resolution or repeal shall also be deemed to amend any local law, 22 ordinance or resolution enacted by such a city imposing such taxes 23 pursuant to the authority of this subdivision, whether or not such taxes 24 are suspended at the time such city enacts its resolution pursuant to 25 subdivision (p) of this section or at the time of such repeal; provided, 26 further, that any such local law, ordinance or resolution and section 27 eleven hundred seven of this chapter, as deemed to be amended in the 28 event a city of one million or more enacts a resolution pursuant to the 29 authority of subdivision (p) of this section, shall be further amended, 30 as provided in section twelve hundred eighteen of this subpart, so that 31 the wireless telecommunications services exemption in any such local 32 law, ordinance or resolution or in such section eleven hundred seven of 33 this chapter is the same as the mobile telecommunication services 34 exemption in subdivision (cc) of section eleven hundred fifteen of this 35 chapter. (iii) Any local law, ordinance or resolution enacted by any 36 city, county or school district, imposing the taxes authorized by this 37 subdivision, shall omit the residential solar energy systems equipment 38 and electricity exemption provided for in subdivision (ee), the commer- 39 cial solar energy systems equipment and electricity exemption provided 40 for in subdivision (ii) and the clothing and footwear exemption provided 41 for in paragraph thirty of subdivision (a) of section eleven hundred 42 fifteen of this chapter, unless such city, county or school district 43 elects otherwise as to either such residential solar energy systems 44 equipment and electricity exemption, such commercial solar energy 45 systems equipment and electricity exemption or such clothing and foot- 46 wear exemption. 47 § 3. Paragraph 1 of subdivision (a) of section 1210 of the tax law, as 48 amended by section 2 of part WW of chapter 60 of the laws of 2016 and 49 subparagraph (i) as separately amended by section 5 of part Z of chapter 50 60 of the laws of 2016, is amended to read as follows: 51 (1) Either, all of the taxes described in article twenty-eight of this 52 chapter, at the same uniform rate, as to which taxes all provisions of 53 the local laws, ordinances or resolutions imposing such taxes shall be 54 identical, except as to rate and except as otherwise provided, with the 55 corresponding provisions in such article twenty-eight, including the 56 definition and exemption provisions of such article, so far as theA. 5683 6 1 provisions of such article twenty-eight can be made applicable to the 2 taxes imposed by such city or county and with such limitations and 3 special provisions as are set forth in this article. The taxes author- 4 ized under this subdivision may not be imposed by a city or county 5 unless the local law, ordinance or resolution imposes such taxes so as 6 to include all portions and all types of receipts, charges or rents, 7 subject to state tax under sections eleven hundred five and eleven 8 hundred ten of this chapter, except as otherwise provided. (i) Any 9 local law, ordinance or resolution enacted by any city of less than one 10 million or by any county or school district, imposing the taxes author- 11 ized by this subdivision, shall, notwithstanding any provision of law to 12 the contrary, exclude from the operation of such local taxes all sales 13 of tangible personal property for use or consumption directly and 14 predominantly in the production of tangible personal property, gas, 15 electricity, refrigeration or steam, for sale, by manufacturing, proc- 16 essing, generating, assembly, refining, mining or extracting; and all 17 sales of tangible personal property for use or consumption predominantly 18 either in the production of tangible personal property, for sale, by 19 farming or in a commercial horse boarding operation, or in both; and all 20 sales of fuel sold for use in commercial aircraft and general aviation 21 aircraft; and, unless such city, county or school district elects other- 22 wise, shall omit the provision for credit or refund contained in clause 23 six of subdivision (a) or subdivision (d) of section eleven hundred 24 nineteen of this chapter. (ii) Any local law, ordinance or resolution 25 enacted by any city, county or school district, imposing the taxes 26 authorized by this subdivision, shall omit the residential solar energy 27 systems equipment and electricity exemption provided for in subdivision 28 (ee), the commercial solar energy systems equipment and electricity 29 exemption provided for in subdivision (ii), the commercial fuel cell 30 electricity generating systems equipment and electricity generated by 31 such equipment exemption provided for in subdivision (kk) and the cloth- 32 ing and footwear exemption provided for in paragraph thirty of subdivi- 33 sion (a) of section eleven hundred fifteen of this chapter, unless such 34 city, county or school district elects otherwise as to such residential 35 solar energy systems equipment and electricity exemption, such commer- 36 cial solar energy systems equipment and electricity exemption, commer- 37 cial fuel cell electricity generating systems equipment and electricity 38 generated by such equipment exemption or such clothing and footwear 39 exemption. Any local law, ordinance or resolution enacted by any city, 40 county or school district, imposing the taxes authorized by this subdi- 41 vision, shall omit the mobile telecommunication services exemption 42 provided for in subdivision (cc) of section eleven hundred fifteen of 43 this chapter, unless such city, county or school district elects other- 44 wise; provided that if such a city having a population of one million or 45 more enacts the resolution described in subdivision (p) of this section 46 or repeals such resolution, such resolution or repeal shall also be 47 deemed to amend any local law, ordinance or resolution enacted by such a 48 city imposing such taxes pursuant to the authority of this subdivision, 49 whether or not such taxes are suspended at the time such city enacts its 50 resolution pursuant to subdivision (p) of this section or at the time of 51 such repeal; provided, further, that any such local law, ordinance or 52 resolution and section eleven hundred seven of this chapter, as deemed 53 to be amended in the event a city of one million or more enacts a resol- 54 ution pursuant to the authority of subdivision (p) of this section, 55 shall be further amended, as provided in section twelve hundred eighteen 56 of this subpart, so that the wireless telecommunications servicesA. 5683 7 1 exemption in any such local law, ordinance or resolution or in such 2 section eleven hundred seven of this chapter is the same as the mobile 3 telecommunication services exemption in subdivision (cc) of section 4 eleven hundred fifteen of this chapter. (iii) Any local law, ordinance 5 or resolution enacted by any city, county or school district, imposing 6 the taxes authorized by this subdivision, shall omit the residential 7 solar energy systems equipment and electricity exemption provided for in 8 subdivision (ee), the commercial solar energy systems equipment and 9 electricity exemption provided for in subdivision (ii) and the clothing 10 and footwear exemption provided for in paragraph thirty of subdivision 11 (a) of section eleven hundred fifteen of this chapter, unless such city, 12 county or school district elects otherwise as to either such residential 13 solar energy systems equipment and electricity exemption, such commer- 14 cial solar energy systems equipment and electricity exemption or such 15 clothing and footwear exemption. 16 § 4. Subdivision (d) of section 1210 of the tax law, as amended by 17 section 4 of part WW of chapter 60 of the laws of 2016, is amended to 18 read as follows: 19 (d) A local law, ordinance or resolution imposing any tax pursuant to 20 this section, increasing or decreasing the rate of such tax, repealing 21 or suspending such tax, exempting from such tax the energy sources and 22 services described in paragraph three of subdivision (a) or of subdivi- 23 sion (b) of this section or changing the rate of tax imposed on such 24 energy sources and services or providing for the credit or refund 25 described in clause six of subdivision (a) of section eleven hundred 26 nineteen of this chapter, or electing or repealing the exemption for 27 residential solar equipment and electricity in subdivision (ee) of 28 section eleven hundred fifteen of this [article] chapter, or the 29 exemption for commercial solar equipment and electricity in subdivision 30 (ii) of section eleven hundred fifteen of this [article] chapter, or 31 electing or repealing the exemption for commercial fuel cell electricity 32 generating systems equipment and electricity generated by such equipment 33 in subdivision (kk) of section eleven hundred fifteen of this article 34 must go into effect only on one of the following dates: March first, 35 June first, September first or December first; provided, that a local 36 law, ordinance or resolution providing for the exemption described in 37 paragraph thirty of subdivision (a) of section eleven hundred fifteen of 38 this chapter or repealing any such exemption or a local law, ordinance 39 or resolution providing for a refund or credit described in subdivision 40 (d) of section eleven hundred nineteen of this chapter or repealing such 41 provision so provided must go into effect only on March first; provided, 42 further, that a local law, ordinance or resolution providing for the 43 exemption described in subdivision (cc) of section eleven hundred 44 fifteen of this chapter or repealing any such exemption so provided and 45 a resolution enacted pursuant to the authority of subdivision (p) of 46 this section providing such exemption or repealing such exemption so 47 provided may go into effect immediately. No such local law, ordinance 48 or resolution shall be effective unless a certified copy of such law, 49 ordinance or resolution is mailed by registered or certified mail to the 50 commissioner at the commissioner's office in Albany at least ninety days 51 prior to the date it is to become effective. However, the commissioner 52 may waive and reduce such ninety-day minimum notice requirement to a 53 mailing of such certified copy by registered or certified mail within a 54 period of not less than thirty days prior to such effective date if the 55 commissioner deems such action to be consistent with the commissioner's 56 duties under section twelve hundred fifty of this article and theA. 5683 8 1 commissioner acts by resolution. Where the restriction provided for in 2 section twelve hundred twenty-three of this article as to the effective 3 date of a tax and the notice requirement provided for therein are appli- 4 cable and have not been waived, the restriction and notice requirement 5 in section twelve hundred twenty-three of this article shall also apply. 6 § 5. Section 1210 of the tax law is amended by adding a new subdivi- 7 sion (q) to read as follows: 8 (q) Notwithstanding any other provision of state or local law, ordi- 9 nance or resolution to the contrary: (1) Any city having a population of 10 one million or more in which the taxes imposed by section eleven hundred 11 seven of this chapter are in effect, acting through its local legisla- 12 tive body, is hereby authorized and empowered to elect to provide the 13 exemption from such taxes for the same mobile communications services 14 exempt from state sales and compensating use taxes described in subdivi- 15 sion (cc) of section eleven hundred fifteen of this chapter by enacting 16 a resolution in the form set forth in paragraph two of this subdivision; 17 whereupon, upon compliance with the provisions of subdivisions (d) and 18 (e) of this section, such enactment of such resolution shall be deemed 19 to be an amendment to such section eleven hundred seven and such section 20 eleven hundred seven shall be deemed to incorporate such exemption as if 21 it had been duly enacted by the state legislature and approved by the 22 governor. 23 (2) Form of resolution: Be it enacted by the (insert proper title of 24 local legislative body) as follows: 25 Section one. Receipts from sales of and consideration given or 26 contracted to be given for purchases of mobile telecommunications 27 services exempt from state sales and compensating use taxes pursuant to 28 subdivision (cc) of section eleven hundred fifteen of the tax law shall 29 also be exempt from sales and compensating use taxes imposed in this 30 jurisdiction. 31 Section two. This resolution shall take effect, (insert the date) and 32 shall apply to sales made and uses occurring on and after that date 33 although made or occurring under a prior contract. 34 § 6. The commissioner of taxation and finance is hereby authorized to 35 implement the provisions of this act with respect to the elimination of 36 the imposition of sales tax, additional taxes, and supplemental taxes on 37 wireless telecommunications services and all other taxes so addressed by 38 this act. 39 § 7. This act shall take effect on the first day of the sales tax 40 quarterly period, as described in subdivision (b) of section 1136 of the 41 tax law, beginning at least ninety days after the date this act shall 42 have become a law and shall apply in accordance with the applicable 43 transitional provisions of sections 1106 and 1217 of the tax law; 44 provided, however, that section three of this act shall take effect on 45 the same date and in the same manner as section 5 of part Z of chapter 46 60 of the laws of 2016 takes effect. 47 § 2. Severability. If any clause, sentence, paragraph, section or part 48 of this act shall be adjudged by any court of competent jurisdiction to 49 be invalid and after exhaustion of all further judicial review, the 50 judgment shall not affect, impair, or invalidate the remainder thereof, 51 but shall be confined in its operation to the clause, sentence, para- 52 graph, section or part of this act directly involved in the controversy 53 in which the judgment shall have been rendered. 54 § 3. This act shall take effect immediately provided, however, that 55 the applicable effective date of Parts A through B of this act shall be 56 as specifically set forth in the last section of such Parts.
