HIDDEN GOLD GIFT PLANNING WITH SAVINGS BONDS

[Pages:9]HIDDEN GOLD GIFT PLANNING WITH

SAVINGS BONDS

By Marc Carmichael

Winkelman, Arizona, had suffered its second "100-year flood" in just five years, and an elderly couple, both retired schoolteachers, were chatting with John Ferree, President of Scottsdale Memorial Health Foundation, about the flood-and a possible planned gift.

"You know, we have some old savings bonds in a tin box out there in the shed," the husband remarked. "They might make a good gift to the hospital. I think there may be a dozen or so, maybe $100 denominations. Let's take a look."

The three of them made their way to the mud-soaked shed and retrieved a stack of still-damp savings bonds from a small lock box. They carefully peeled off not 12 but 53 Series E savings bonds, discolored from the floods but still legible. And the denominations were all $1,000, not $ 1 0 0 . . . worth nearly $150,000 all told. Many of the bonds dated back to 1953.

The Winkelman couple have now both passed away, bequeathing all of their estate to charity; along with a memorable story about U.S. savings bonds and the role they can play in philanthropy.

THE UBIQUITOUS SAVINGS BOND

Treasury figures indicate that more than 55 million Americans own U.S. savings bonds. The Treasury estimates that approximately one-third of all American families own at least one savings bond, and the total value of bonds being held currently exceeds $198 billion. Older individuals always seem to have some, tucked away in a bureau drawer or safe deposit box. More than 58 million bonds were sold in a recent year, and the dollar amounts accumulated by some savers can be astonishing.

A faculty member at the 1998 Ohio CLE Institute observed during dinner that the father of one of his clients died owning at least $1 million in savings bonds. The next week he sent the following update:

"Since you were interested in the topic of savings bonds in estates, I did some factual research. The living trust of which my client is

a beneficiary owned Series E and Series H H U.S. savings bonds valued at time of death at $3,047,366."

The author now regularly poses the question at meetings of estate planners: "Has anyone ever worked with a client whose estate contained large numbers of U.S. savings bonds?" Invariably advisers report clients who own bonds totaling in the six figures. The numbers of bond owners and the value of the bonds they hold have made U.S. savings bonds the nation's most widely held appreciated security.

BOND BASICS

Three general types of bonds are currently sold by the Savings Bond Division of the Department of Treasury: Series EE, Series I and Series HH bonds. 1 Bonds traditionally have been purchased through financial institutions and employer-sponsored payroll savings plans and redeemed through financial institutions. The Treasury is currently in the process of expanding the purchase and redemption of savings bonds into the Internet world through a program called TreasuryDirect, which allows buyers the convenience of a book-entry (electronic) bond account linked to a designated savings or checking account for ease of purchase and redemption.

Series EE savings bonds are bought at a discount (a $100 bond costs $50 initially) and they are guaranteed to double in value upon reaching "original maturity"-20 years after the issue date. If insufficient interest has accumulated, the Treasury will make up the difference, in effect guaranteeing a minimum interest rate of 3.6 percent for bonds held 20 years. EE bonds are always free of state and local income taxes and the interest (2.66 percent through October 2003) accumulates free of federal income tax, as well, for cash-basis taxpayers who do not elect to report their bond interest annually as it accrues. Interest is credited monthly and is compounded semiannually. The bonds continue to earn interest until "find maturity"-30 years from the date of issue.

, / a e a ~ O"

THE JOURNAL OF GIFT PLANNING

Taxation generally occurs only when the bonds are cashed, reissued to another person or reach final maturity. But owners have the option to report interest as it accrues annually. 2 Owners also have the option of exchanging EE bonds for H H bonds at final maturity and deferring reporting the accrued interest for up to 20 more years. Series E bonds, the predecessor to EEs, were issued until 1980 and are widely held, although many have stopped earning interest.

Series I bonds are the newest variety and are purchased at face value (a $1,000 bond costs $1,000), earning interest at a rate that

is indexed for inflation (4.66 percent through October 2003).

Interest is credited monthly and compounded semiannually, but tax is generally deferred until redemption, in the same manner as Series EE bonds. Series I bonds earn interest until they reach final maturity at 30 years from the issue date. They cannot be exchanged for HH bonds.

Series H H bonds are current income securities that pay interest semiannually by direct deposit for a maximum of 20 years (current interest rate of 1.5 percent). Sale of Series H H bonds is scheduled to be discontinued in mid-2004. Series H bonds were issued prior to 1980 and generally had 30-year maturities.

Interest on "college education" savings bonds can be tax free if certain requirements are met.

Extensive consumer information about savings bonds is available at (including a link to a kids' website on bonds!), and legal aspects of bonds are discussed in a publication

of the Bureau of Public Debt, LegalAspectsof UnitedStates SavingsBonds, found at .

Bonds may be subject to heavy federal income taxes and state and federal "death taxes" in a person's estate. For example, heirs who receive $100,000 in savings bonds from a decedent's estate will one day have to pay income tax on as much as $50,000 or more of built-up interest. Furthermore, the full $100,000 could be subject to federal estate tax, leaving only a fraction of the bonds' value.

Many donors would prefer to make gifts of bonds, whether they have stopped earning interest or not. But Treasury regulations rigidly restrict the lifetime reissue of bonds, limiting transfer to family members and "personal estate trusts," such as revocable living trusts)

A curious 1980 private letter ruling (the only known ruling on lifetime transfers of savings bonds) involved a donor who proposed to convert Series E bonds to Series H bonds, which would be then be issued in the name of a charitable organization. The donor had never elected to treat the annual increment in

value (interest) as income under I.R.C. ~454. Normally, a

"rollover" of E/EE bonds into H / H H bonds continues deferral of interest on the bonds until maturity. But if reissue of bonds in the name of another is also involved, "taxes happen." Citing Rev. Rul. 55-278 (1955-1 C.B. 41), the IRS ruled that the donor would have to report all the buildup of interest in the E bonds when they were exchanged for H bonds issued in the name of charity. On the bright side, the IRS ruled that the amount of the contribution would be the fair market value of the Series H bonds on the date of the contribution. 4

It is doubtful that the Treasury would ever have reissued E/EE bonds as H / H H bonds in the name of charity, based on the regulation cited above. However, donors can contribute the cash proceeds from matured bonds and reduce their taxes, too-if they "itemize" their tax deductions. The tax results of cashing and contributing bonds would be exactly the same as the result in the 1980 ruling. Donors would report income but receive contribution deductions that, theoretically, would reduce the donor's taxes, or at least keep the gift from increasing the donor's tax. The danger is that donors who give bond proceeds and customarily use the standard deduction will report interest income but be unable to use the charitable deduction. Consider the 2003 standard deductions:

SAVINGS BONDS IN LIFETIME GIVING

Bonds are often "hidden assets for giving" that people have simply forgotten about and likely would not miss if they gave them to charity. Owners are often surprised to discover that some of their savings bonds have stopped earning interest, and they may be interested in bringing new life to those bonds as planned gifts.

5uppose a widow age 65 cashes an EE bond worth $1,000 for which she paid $500, and contributes the proceeds to charity. She would report $500 in interest but be entitled to a $1,000 contribution deduction. The deduction would doher no good, however, if her total itemized deductions added up to only $4,000. Her taxes actually go up as a result of a charitable gift, which is not the way planned giving is supposed to work. Such a

THE JOURNAL OF GIFT PLANNING

~

0 "~

donor should hold back some bond proceeds sufficient to pay the taxes, perhaps $125 in a 25 percent tax bracket, and give charity the difference ($875). Of course, a donor who gives bonds worth $50,000 will thereby have itemized deductions well above the threshold for itemizing. But gift planners must also weigh the effect of the contribution deduction ceilings (50 percent of adjusted gross income for gifts of cash) and the deduction cutbacks for high-income taxpayers to determine whether the donor will be harmed.

Donors who plan to cash and contribute savings bonds need planning assistance, especially if they plan to keep some bonds but give others. They should retain bonds that are paying the highest rates of interest and cash those with low yields. Donors also need to make certain that they redeem bonds at the proper time. In many cases, bond interest is credited at six-month intervals (interest is credited monthly for bonds purchased after May 1, 1997, and for certain other issues.) Cashing a bond just before interest is credited could cost the donor and charity up to six months' interest. Series I bonds and EE bonds cashed before five years will result in a threemonth interest penalty.

Figuring the interest rates on particular bonds and determining the best time to redeem bonds can be daunting and beyond the ken of most people (including many bank personnel who work with bonds). One source of help is the website mentioned earlier (), which provides bond earnings reports, calculations of current redemption value, an online savings bond redemption calculator and a program called "Savings Bond Wizard."

Another resource is the acknowledged guru of U.S. savings bonds, Daniel J. Pederson, author of Savings Boneh: When to Hold, When to Fold and Everything in Between, an overview of the do's and don'ts of savings bonds, from tiffing to the merits of I-Bonds versus EEs. He has also written U.S. Savings Bonds: The Definitive Guidefor FinancialProfessionals. Pederson's book has a discussion on tracking the value of bonds. His company (The Savings Bond Informer, Inc.) also provides written reports for bondholders and their advisers, including specific values, interest rates, timing issues,

maturity dates and extended maturity dates for each bond a person owns.5

Once donors know which bonds to cash and when to cash them, they can be redeemed at an authorized financial institution (40,000 paying agents are approved by the Treasury Department) upon furnishing proper identification. Unlimited amounts of E, EE or I bonds can be redeemed at an institution where the owner has had an account for more than six months or is well known to staff. HH bonds must be sent to a Federal Reserve Bank for redemption, with assistance from the owner's financial institution. Bonds purchased after January 2003 cannot be redeemed until 12 months after issue. Donors can authorize charities to be attorneysin-fact to redeem bonds on their behalf, so long as the power of attorney complies with state law.6

Another redemption option, employed by one organization when bonds are used to fund gift annuities, is the use of Form PD F 1522E, "Special Form of Request for Payment of U.S. Savings

Continued on page 2 6

)7

THE JOURNAL OF GIFT PLANNING

Carmichael, continuedfrom page 7

and Retirement Securities Where Use of a Detached Request Is Authorized." The form can be downloaded at publicdebt.bpd/bpdforms.htm and enables the donor to send bonds to the charity by Registered Mail. The donor lists the bonds to be redeemed on the form and sends it separately to the organization, listing the bond owner as payee. The form must have been signed and certified by an officer of the donor's financial institution. Under Treasury regulations, the organization would need a limited power of attorney to complete the redemption process.

CONVERTING BONDS TO "LIFE INCOME" GIFTS

One way to offset tax liability when owners cash savings bonds is to create a gift annuity or other "life income" gift arrangement that will provide future support for an organization, lifetime income to the donor or another person, and a charitable deduction that may eliminate all taxes caused from cashing the bonds. Pooled income funds and charitable remainder trusts-and especially charitable gift annuities-can offer significant benefits, including larger payments than the interest available from H H bonds.

A man we'll call Herbert calls and tells us the following: "I recently ran across a packet of U.S. savings bonds that I had been accumulating since World War II. It was quite a stack, too-war bonds, Series E and EE bonds. Some were so old I think they had stopped earning interest. I showed the bonds to my sister, Helen, and we agreed that something should be done with them. I checked with the bank and here's the situation: The bonds are worth $25,000, and if I cash them in I will be taxed on about $14,000 of interest. Is there some way I can give these bonds to charity, avoid any tax, get a deduction and obtain income, too?"

We get back to Herbert with the following answers: U.S. savings bonds can be transferred during life only to family members, not to a qualified charity. So to use them in a gift arrangement, Herbert would have to cash the bonds and give charity the proceeds. That means he would have to report all the built-up interest on his next tax return. However

We can't prevent Herbert from having to report the interest for tax purposes. But we can cover the taxes if he transfers the $25,000 cash proceeds in exchange for a charitable gift annuity. Herbert is 75, and if he receives a 7.1 percent annuity ($1,775 a

year), he will be entitled to a charitable deduction of about $9,759 (4 percent A.ER.)-which offsets a substantial part of the $14,000 of built-up interest. The $14,000 interest is not subject to state and local tax. His first $1,775 in annual payments will provide the cash flow to pay any remaining tax. The charitable deduction means that Herbert actually has more money left from the bonds to produce income than if he had cashed them and reinvested the proceeds. True, he could exchange some Series EE bonds for Series H H bonds and receive (a princely) 1.5 percent semiannual payment from the Treasury. But no charitable gift occurs, and Herbert (or his heirs) eventually would be taxed on the buildup of interest on the HH bonds. And his 7.1 percent annuity payments will be about two-thirds tax free during his life expectancy.

If the charitable deduction is insufficient to cover the donor's tax liability; the donor might consider accepting a lower gift annuity payout. If Herbert takes a 5 percent annual payout, his charitable deduction increases to $14,579. Alternatively, donors might defer the first payment for a few years (which increases their deductions) or hold back part of the proceeds to pay any tax.

Pooled funds offer many of the same advantages as charitable gift annuities for donors who wish to cash bonds, give the proceeds and retain lifetime income. Gifts can be large or small (most organizations have gift minimums as low as $5,000), and charitable deductions may be larger than those for gift annuities, in the current low-interest-rate environment. Pooled income funds cannot offer payments that are partially tax free, but payouts from some funds indude dividend income, which is currently taxed at a maximum 15 percent rate.7

Annuity trusts and unitrusts offer flexibility to donors who own savings bonds in substantial quantities. Donors can select payouts and trust terms that leverage the charitable deduction so as to offset the interest reported from cashing bonds.

SAVINGS BONDS: THE BEST BEQUEST?

Retirement accounts receive most of the attention when gift planners discuss charitable bequests of "IRD" (income in respect of a decedent). But retirement accounts are not the only source of IRD. Many older Americans own significant amounts of Series E, EE, H, H H and I savings bonds, which are IRD assets that should be used for charitable bequests.

Where possible, donors should bequeath to charity property that would cause tax problems for other beneficiaries. This generally means IRD: items of income earned by a decedent before death but paid to his or her estate or heirs after death. Unlike capital gain property, IRD assets receive no step-up in basis to fair

market value at death. IRD income is indudable both in the taxpayer's gross estate8 and in the estate's income.9 Heirs who inherit IRD assets generally will owe income tax when they receive IRD income. 1? Congress has provided an IRD income tax deduction to alleviate the "double tax" presented by having IRD subject to both federal estate tax and income tax. 11The deduction equals the amount of estate tax attributable to the IRD received by the heir and is an itemized deduction that is not subject to the 2 percent floor on miscellaneous deductions. 12

Charities usually do not pay income taxes and therefore keep every dollar of such tax-burdened bequests. Furthermore, a bequest of lRD can create both an estate tax charitable deduction and income tax savings for the estate. 13 It's important, from a tax standpoint, for a donor's will or trust to make specific bequests of items of IRD to charity, or pass IRD assets to charity as a residuary bequest or under other bequest language that ensures favorable tax treatment. With retirement accounts, a donor can change the death beneficiary to a qualified charity; beneficiary designations also are possible with revocable living trusts that contain IRD. Satisfying pecuniary bequests to charity out of IRD assets will generate an estate tax charitable deduction but the estate will have to include the IRD in its income. 14

257

THE JOURNAL OF GIFT PLANNING

Savings bonds that are

specifically bequeathed to a

tax-exempt organization (or distributed from a revocable living trust) will avoid

income taxes and also qualify for an estate tax

charitable deduction.

BEQUESTS OF SAVINGS BONDS BY WILL OR LIVING TRUST

Bonds may be transferred to charity at death in only two ways: under the terms of the donor's will or as a distribution from a revocable living trust. Why can't charity be listed as a co-owner or death beneficiai'y on the bond itself?.

"The issue or reissue of a bond in the name of an organization (charitable and others) as a coowner or beneficiary is not permitted; such forms of registration are limited to natural persons. Reissue of a bond in the name of an organization to designate another organization as owner is not permitted, but a bond that an organization receives as a distributee of a decedent's estate may be reissued in its name."

(LegalAspectsof U.S. SavingsBonds)15

Treasury regulations do permit one particular "charity" to be named co-owner or beneficiary: The U.S. Treasury; 16 and gifts do occur. Last year Americans donated $744,675 to be used to reduce the public debt, which was down from the $1,645,082 given in 2001 (apparently even the government has trouble fund raising during a bad economy). However, patriotic donors are not permitted to change their minds: "Restrictions on reissue... (b) United States Treasury. Reissue may not be made to eliminate the United States Treasury as coowner or beneficiary. ''17

Series E, EE, H, H H and I bonds may be issued or reissued in the name of a trustee of a revocable trust, if the donor is the lifetime (income) beneficiary and is considered the owner of the trust under the grantor trust rules. For example, an HH bond could be registered to: "ABC Church, trustee under agreement

with Mary Jones, dated 12/1/95, 12-3456789."

Mary's tax situation would be the same as if the trust never existed. But her house of worship or other charity could be the remainder beneficiary of the trust and thus receive the bonds at her death.

Bonds can be left to charity in a will or through a revocable living trust only if the bonds do not have a surviving co-owner or death beneficiary.

Savings bonds registered in either co-ownership or beneficiary form become the sole property of the survivor, irrespective of the terms of any will. Gift planners must work with donors to have bonds reissued without inclusion of any death beneficiary or co-owner. Donors can be assured that removing death beneficiaries or coowners who did not furnish funds for the bonds' purchase will not be a taxable event.

Savings bonds that are specifically bequeathed to a tax-exempt organization (or distributed from a revocable living trust) will avoid income taxes and also qualify for an estate tax charitable deduction. Several bequest options should work:

1. "I bequeath the following U.S. savings bonds to XYZ Charity" (followed by bond descriptions, including denominations and serial numbers).

2. The will or trust states that 'TKLLmy U.S. savings bonds are to pass to charity."

3. The bonds are part of the residue of the estate and pass to charity as sole residuary beneficiary.

4. The bonds pass under a general instruction that charitable bequests will be satisfied with assets deemed to be income in respect of a decedent. Christopher R. Hoyt, Professor of Law at the University of Missouri (Kansas City), has suggested the following phrase:

"I instruct that all of my charitable bequests and gifts shall be made, to the extent possible, from property that constitutes 'income in respect of a decedent'as that term is defined in The Internal Revenue Code. ''18

Where a decedent directed that a specific dollar amount pass from her revocable living trust to charity and the trustees proposed to satisfy the bequest by distributing Series E and Series H bonds with unreported increments in value, the IRS ruled that the distribution of the savings bonds would be considered a distribution of cash to charity and a purchase of bonds, with the increase in value included in the gross income of the trust. 19 In another ruling, the IRS said the trust must recognize

THE JOURNAL OF GIFT PLANNING

~

20 ?

the unreported increment as IRD to the extent the bonds are used to satisfy a specific dollar bequest if the bonds are not directed to be paid to charity.20 But where the entire residuary estate passed to four named charities in varying amounts and savings bonds with unreported interest were included in the residue, the estate was not taxed on the IRD when the executor transferred the bonds to one of the charities. Both the will and state law allowed the executor to make non-pro rata distributions of capital assets, so the transfer was not a disposition by the estate followed by an exchange between beneficiaries.21

The IRS confirmed the tax wisdom of leaving U.S. savings bonds to charity in a private ruling where the donor left the residue of his estate to five charities. Included in the residue were Series E and H H savings bonds with large amounts of unreported interest. The executor wished to distribute thebonds directly to the charities and asked the IRS about the tax consequences. The Service replied that transfer of the bonds to charity would not result in IRD. The interest would be included in the gross income of the charities in the year they dispose of the bonds, but of course the charities are exempt from tax.22

Private foundations are subject to a two percent excise tax on net investment income. 23 In Rev. Rul. 80-118 the IRS ruled that where a decedent's estate distributed Series E U.S. savings bonds to a private foundation, the increase in value of the bonds was gross investment income to the foundation when the bonds were redeemed.

BEQUESTS OF BONDS TO CHARITABLE REMAINDER TRUSTS

Occasionally one hears of a gift situation that compels the listener to declare: "This is what planned giving is all about!" Here are the facts: A 77-year-old woman, who has always lived frugally, amassed the startling sum of just over $620,000 in U.S. savings bonds (Series E and EE). Her estate, including the bonds, totals approximately $1,300,000. She's unmarried, but has several brothers and sisters she wants to benefit, as well as a Catholic college and her parish.

The gift planning officer didn't know the exact amount of unreported interest tied up in the savings bonds, but it undoubtedly exceeded $300,000. The bonds will be treated as IRD in the woman's estate or in the hands of family members who receive the bonds-meaning they will be subject to income tax on all accumulated interest.

2~0

THE JOURNAL OF GIFT PLANNING

Part of the bonds' value also would be subject to federal estate tax, since her total estate exceeds the $1,000,000 currently sheltered by the unified estate tax credit.

Solution? The gift planner suggested the donor establish a unitrust in her will and specify that the trust will be funded with the savings bonds. The trust would last for 20 years and make payments to her brothers and sisters (or to the chil&en of any brother or sister who died prior to termination of the trust).

While there are no cases or rulings invoMng transfer of savings bonds to unitrusts, such a plan should eliminate income taxes on the savings bonds when they are redeemed by the trustee of the unitrust, which is tax exempt. The interest on the bonds likely will be passed through to the trust beneficiaries as part of their annual unitrust payments, under the four-tier system, and taxed as ordinary income. But there would be no depletion of the trust corpus from tax. Furthermore, the donor's estate is entitled to an estate tax charitable deduction. If the trust has a six percent payout, roughly 30 percent of the bonds' value will be a deductible bequest ($180,000). That deduction, plus reasonable estate settlement costs, will reduce her taxable estate below the $1,000,000 tax-sheltered level.

Note: If the donor's estate is subject to federal estate taxes, beneficiaries apparently will not be able to take advantage of a tax break usually available to recipients of lRD assets. The IRS has ruled unfavorably in a case involving retirement accounts where the account passes at death to a charitable remainder trust. Heirs normally receive an income tax deduction for estate taxes that were owed on an IRA or other retirement account.24 Now, says the IRS, if the IRA passes to a CRT, the deduction will belong to the trust, not passed through to the income beneficiaries. The result is to convert part of the trust's income (IRD) to tax-free corpus, which the income beneficiaries may be unlikely ever to access, under the "worst-in, first-out" four-tier system of CRT taxation.25The same reasoning would also seem to apply to savings bonds bequeathed to a CRT.

TESTAMENTARY POOLED INCOME FUNDS AND GIFT ANNUITIES

It is questionable whether testamentary transfers of savings bonds to pooled income funds would result in the same IRD tax avoidance as is available with charitable remainder trusts. Pooled income funds are not tax-exempt trusts and redemption of savings bonds by a fund would produce taxable income.

annuity.26 In the IRA-to-gift-annuity ruling, the IRS said that the donor's estate would receive an estate tax charitable deduction for the value of the IRA, less the value of the beneficiary's annuity. The charity would not have unrelated business taxable income and the IRA would not be taxable income (IRD) to the estate if charity had been named IRA death beneficiary. The IRS &dined to rule on how the annuity payments would be taxed. If the IRS applies its IRA reasoning to bequests of savings bonds for gift annuities, the tax and financial results should be attractive. But private letter rulings do not represent binding precedent. Seemingly, the taxation of payments from testamentary gift annuities funded with savings bonds should be favorable, since bonds, unlike most IRAs, always have a cost basis. A reasonable approach would be to pro-rate any unreported interest (IRD) between the charitable bequest portion of this transaction and the present value of the annuity provided to the decedent's beneficiary. Thus, part of the IRD would escape tax and the rest would be reported by the beneficiary; ideally over his or her life expectancy. Under this theory, the beneficiary might have some tax-flee return of principal during his or her life expectancy. An IRD deduction against income taxes should be available to the beneficiary if the IRD reported from the bonds gave rise to federal estate tax.

PROCEDURE WHEN CHARITIES RECEIVE BEQUEATHED BONDS

Paying agents are authorized to pay bonds upon the request of legal representatives of decedents' estates. Charities that receive bonds from an estate may request payment or reissue in the charity's name upon showing a certified copy of the executors court-approved final report, the decree of distribution or other pertinent court records. The charity's representative must furnish proof that he or she is an authorized agent of the organization.27

MARKETING IDEAS

What should charities be saying to donors about savings bonds? Here are some ideas:

Curses! Savings bonds are "tax-cursed" assets that should be left to our organization through your will or living trust. Bonds that pass to family members will be subject to "death taxes"

based on the date ofdeath valueand to income taxes on the

buildup of interest. Our organization, however, can put every dollar to use in our programs, free of all taxes.

Bequests of bonds to charities in exchange for gift annuities also raise sticky questions, although there is a favorable private letter ruling on leaving an IRA to charity for a testamentary gift

Sharing Bequests. If surviving family members will need savings bonds for their financial security, donors should consider leaving the bonds to a trust that will provide them

THE JOURNAL OF GIFT PLANNING

~

o?C "

 ................
................

In order to avoid copyright disputes, this page is only a partial summary.

Google Online Preview   Download