QB Kirk ‘Nightmare On’ Herbstreit (Frosted Quips, Afraid of THE Lunatic Fringe)

[sparcboxbuck]

"Does the Big 10 get points for losing all its bowl games?"

Not appropriate in any situation.

Yeppers... lost me for forever with that one right there.

 

[OSU_D/]

"How about we narrow it down to a specific instance that I want to use to fit my argument" is what you should have said.

I was showing that by broadening or narrowing the scope there are many more statistics out there than what you mentioned. See below about who has more statistics.

Bottom line is if the SEC were as vastly superior to the B10 as you are trying to say it is they should be able to do better than a sub .500 record against the B10 in Bowl games....period.

When the WORST thing you can say about another conference is that they go .500 against the Big 10 that conference is doing a good job. Head to head is a limited scope of 8 games and while it provides some information it does not govern which conference is doing much better in college football overall.

As far as pulling many more stats to favor the SEC I think you are confusing the definition of "stat" and "opinion".

Really? Because you have two statistics that help support the big 10. Where as I can rely on Bowl Games overall, championship games, championship games head to head (B10 v SEC), the # of championships won by conference, the conference which has won 3 in a row in the bcs era, the conference which has won the last 3. Shall I go on?

Is the SEC the best conference right now? Sure it is. Is it "10 billion times better" ? No. Go easy on the hyperbole and remember that these things are cyclical.

Yes that was hyperbole - I am not on the airwaves trying to be impartial so I feel entitled to use it on a message board to prove a point. But this 3 year cycle, its going to be one very long cycle if the Big 10 doesn't get off its rear and compete through better coaches and recruits (which also means faster recruits as part of that.) Honestly, would you want the SEC coaches and recruiting classes or those of the Big 10?


I will say this... I don't support Herbie when he goes he steers people away from certain schools. Last I checked I don't hear Corso saying he won't have his grandkids go to FSU even though their offense has stunk for 8 years now.

 

[Jaxbuck]

I was showing that by broadening or narrowing the scope there are many more statistics out there than what you mentioned. See below about who has more statistics.

Its called sample size. From 1998-2008 the SEC and B10 have played head to head 2-3 times a year in Bowl games for a total of 29 games. The B10 leads 15-14. That is a fact.

I take the results of a larger sample size like that than anything a 2 game sample shows.

When the WORST thing you can say about another conference is that they go .500 against the Big 10 that conference is doing a good job. Head to head is a limited scope of 8 games and while it provides some information it does not govern which conference is doing much better in college football overall.

You are the one saying you buy into the fact the SEC is clearly head and shoulders better than the B10. I continue to point out that this theory fails at the first logic test it comes to. The supposedly clear cut superior SEC has a losing record against the B10 in Bowl games. If they are that much better then how is this possible?

If the B10 played the Big East 2-3 times every Bowl season for over a decade and came out with a losing record to show from it would you be running around telling everyone how much better we were than the Big East? Only if you ignore the facts and buy into the ESPN/SEC hype.

Really? Because you have two statistics that help support the big 10. Where as I can rely on Bowl Games overall, championship games, championship games head to head (B10 v SEC), the # of championships won by conference, the conference which has won 3 in a row in the bcs era, the conference which has won the last 3. Shall I go on?

Yes please do go on right after you answer my question from above and read what I said about sample size.

Bowl games overall is hardly relevant, what have they done head to head?
Championship games? I'll take a 30 game sample size over a 2 game sample size thanks.

As far as the SEC winning the last 3 in a row, congrat's to them. Nowhere have I said they aren't the best right now. My point is they are nowhere near as vastly superior as you or ESPN want to believe.

Yes that was hyperbole - I am not on the airwaves trying to be impartial so I feel entitled to use it on a message board to prove a point. But this 3 year cycle, its going to be one very long cycle if the Big 10 doesn't get off its rear and compete through better coaches and recruits (which also means faster recruits as part of that.) Honestly, would you want the SEC coaches and recruiting classes or those of the Big 10?

3 years isn't that long of a cycle. I remember hearing the same shit about the B10 vs the PAC 10 for years. Go look up the history of the Rose Bowl games, 10-15 years of dominance in the cycles there. All through the 80's it was the NFC being better than the AFC, the western conference in the NBA was dominant over the eastern confernce etc etc etc.

It all evens out.

 

[OSU_D/]

You are the one saying you buy into the fact the SEC is clearly head and shoulders better than the B10. I continue to point out that this theory fails at the first logic test it comes to. The supposedly clear cut superior SEC has a losing record against the B10 in Bowl games. If they are that much better then how is this possible?



As far as the SEC winning the last 3 in a row, congrat's to them. Nowhere have I said they aren't the best right now. My point is they are nowhere near as vastly superior as you or ESPN want to believe.

I need to get some work done today so I'll just narrow my arguments down. Ohio State v Wisconsin in the BCS era. I would say that OSU has been the better program. Wouldn't you? However, head to head in the BCS era Wisconsin leads the series 4-3. However, we have more people drafted, are definitely better athletes/faster, have more championships, more big 10 championships etc etc. This is akin to your Big 10 argument. I'll go all day on sample sizes if you want, too. Overall bowl games are an even great sample size.

Is the SEC vastly superior to everyone, no. Are they vastly superior to the Big 10.... despite your Wisconsin-like statistic imho, yes.

 

[Jaxbuck]

I need to get some work done today so I'll just narrow my arguments down. Ohio State v Wisconsin in the BCS era. I would say that OSU has been the better program. Wouldn't you? However, head to head in the BCS era Wisconsin leads the series 4-3. However, we have more people drafted, are definitely better athletes/faster, have more championships, more big 10 championships etc etc. This is akin to your Big 10 argument. I'll go all day on sample sizes if you want, too. Overall bowl games are an even great sample size.

Is the SEC vastly superior to everyone, no. Are they vastly superior to the Big 10.... despite your Wisconsin-like statistic imho, yes.

You say you can go all day about sample size but continue to try and draw conclusions from small ones while dissmissing a larger one. Playing 2-3 games a year head to head over a span of 11 years is about as good a sample as you are ever going to get in football.

It eliminates the outliers, luck and the ups and downs. It smoothes everything out. Citing 7 games played over that same span between 2 teams that don't even play anually is apples and oranges. Drawing a sweeping generalization from 2 games played is just dumb.

The biggest part of using stats is being able to properly interpret what they are telling you. Trying to find stats that fit a predetermined argument isn't the way to do it.

Bottom line is we can just let this go because obviously you are one of those people that aren't going to let the facts get in the way of a good opinion. Florida and LSU beat OSU so in your mind the SEC < Big 10. I'm showing you facts to the contrary and you just don't want to let go of the opinion you have already formed. There really is no need to go on from here.

BTW to get back to the topic of the thread, Herbie lost me back in 2003 with that picture of him decked out in maize and blue, wearing a scUM hat and mucking it up with their band. He can rot in hell for all I care after that.

 

[zincfinger]

Personally, I think most of these SEC superiority vs. the BigTen generalizations are off-base. The SEC is superior, but in one area only: a greater number of top-tier programs. The top-tier programs they have are not on an individual basis superior to the BigTen's top-tier programs, they merely have more of them. The BigTen has 3 program's that are realistically capable of winning a national championship in any given year. The SEC has probably six. And that results in a higher chance of having a couple of excellent teams every year, and more favorable across-the-board bowl matchups. If Alabama, Tennessee, and LSU are mediocre in any given year, there's always UF, Auburn, and UGa to pick up the slack. If OSU, UM, and PSU are mediocre - no offense to Wisconsin, Illinois, and Iowa/MSU, but they're just not in the same category generally (I could maybe buy that Wisconsin and Georgia are comparable, but the overall point still stands).

Greater depth of elite programs. That's the SEC's superiority. As for the notion that any SEC program has generally superior speed and athleticism to OSU, PSU, or UM - complete baloney in my opinion.

 

[Steve19]

I need to get some work done today so I'll just narrow my arguments down. Ohio State v Wisconsin in the BCS era. I would say that OSU has been the better program. Wouldn't you? However, head to head in the BCS era Wisconsin leads the series 4-3. However, we have more people drafted, are definitely better athletes/faster, have more championships, more big 10 championships etc etc. This is akin to your Big 10 argument. I'll go all day on sample sizes if you want, too. Overall bowl games are an even great sample size.

Is the SEC vastly superior to everyone, no. Are they vastly superior to the Big 10.... despite your Wisconsin-like statistic imho, yes.

Well, over the longer term, Ford would be way ahead of Toyota or Honda, but which would you drive now?

You are ignoring the fact that other posters have show you that your claim that the SEC is so much better than the Big Ten is flawed because the Big Ten has won the head to head matches in recent years. If you want to claim that the best of the SEC has beaten the best of the Big Ten in the last three years, then I think there is little argument.

As everyone has said, these things go in cycles. Give it a couple of years and let's see where we all are.

 

[WaitingforKickoff]

According to Scout's rankings, 12 out of the top 30 defense tackles are from SEC states. That's 40%.

Of the rest, three each from Texas and California, and two more from Arizona. Guess which school the Arizona kids usually look at?

 

[MililaniBuckeye]

Is the SEC vastly superior to everyone, no. Are they vastly superior to the Big 10.... despite your Wisconsin-like statistic imho, yes.

Check your ding, brainiac...

 

[OSU_D/]

Check your ding, brainiac...

Most people left the name calling behind in grade school instead of doing it on the rep page.

I suppose you think Wisconsin has had a better program than OSU during the BCS era since they have a 4-3 head to head over OSU during that time period? It's the same as using only Big 10 v SEC head to head in bowl games.

 

[Best Buckeye]

:topic: Maybe it's time to get this thread back to Herbie.

 

[Jaxbuck]

Most people left the name calling behind in grade school instead of doing it on the rep page.

I suppose you think Wisconsin has had a better program than OSU during the BCS era since they have a 4-3 head to head over OSU during that time period? It's the same as using only Big 10 v SEC head to head in bowl games.

No its not the same thing, not by a long shot but you obviously aren't getting anything anyone is trying to show you so I don't know why I'm bothering typing this.

 

[MililaniBuckeye]

Most people left the name calling behind in grade school instead of doing it on the rep page.

Then allow me to call you a dipshit right here.

I suppose you think Wisconsin has had a better program than OSU during the BCS era since they have a 4-3 head to head over OSU during that time period? It's the same as using only Big 10 v SEC head to head in bowl games.

No, I don't, but you can't use our series with Wisconsin in the same manner as our conference's performance against another conference in bowl games.

First of all, we don't trail Wisconsin 4-3 in the "BCS era" which began with the 1998 season...we're tied 4-4 (we won in 2000, 2002, 2007, and 2008, and Wisconsin won in 1999, 2001, 2003, and 2004). At least get your facts straight.

Second, the head-to-head bowl game series with the SEC covers a continguous timeframe (a Big Ten team has played an SEC team in a bowl game every single year in the timeframe), whereas our series with Wisconsin does not (we didn't play Wisconsin in 1998, 2005, or 2006).

Third, our head-to-head bowl games against the SEC have multiple matchups per year, allowing a conference having a bad game by one of its teams to offset that with a victory by another one of its teams, whereas our games against Wisconsin are a once-a-season thing and are more affected by pre-game injuries and other factors.

 

[Buckskin86]

Herbstreit 'fire' puts focus on IRS dispute
Tax deduction denied to couples who gave houses for fire drills
Thursday, July 23, 2009
By Kathy Lynn Gray
THE COLUMUS DISPATCH

UPPER ARLINGTON FIRE DIVISION
After Kirk and Allison Herbstreit bought this house at 2321 Onandaga Dr., they let the Upper Arlington Fire Division burn it down for training, then built a new home. Such donations used to rate a tax deduction.

Kirk Herbstreit took on the big boys when he was Ohio State University's quarterback in the early 1990s. Now, he's taking on a giant: the Internal Revenue Service.

In March, the Buckeye-turned-ESPN commentator sued the IRS for rejecting a $330,000 tax deduction he and his wife, Allison, took for donating their house at 2321 Onandaga Dr. to the Upper Arlington Fire Division.

The donation -- and the deduction -- have been common for at least two decades for Upper Arlington residents who wanted to build new homes on property where old homes resided. Firefighters have used the old houses for training and burn-down exercises.

Columbus lawyer Terry Grady said the IRS didn't challenge the deductions until 2004 -- the year the Herbstreits donated their house.

"People have been led to believe (the practice) is sanctioned by the IRS," said Grady, who sued the IRS on behalf of the Herbstreits and another Upper Arlington couple, James and Lori Hendrix.

The Hendrixes donated their house at 2580 Sherwin Rd. to the Upper Arlington fire department in 2004. The IRS rejected the $287,400 deduction after an audit and charged the couple $125,053 in back taxes and interest.

For the Herbstreits, the IRS decision, also after an audit, meant $134,606 in back taxes and interest.

Both couples paid what the IRS said they owed and now are suing to get the money back.

The Columbus Dispatch : Herbstreit 'fire' puts focus on IRS dispute

 

[LightningRod]

Interesting case. There is a case that was decided in 1975 that has somewhat similar facts to Herbie's case where a taxpayer was permitted to take a charitable contribution deduction for donating a partially burned building to a volunteer fire department for training purposes. The case citation is [FONT=&quot]Morris N. Scharf and Frances S. Scharf v. Commissioner, U.S. Tax Court, T.C. Memo. 32,243(M), 32 T.C.M. 1247, T.C. Memo. 1973-265, (Dec. 4, 1973)[/FONT][FONT=&quot][/FONT]

[FONT=&quot]2. Donation of Damaged Building to Fire Department.[/FONT]
[FONT=&quot]Petitioner seeks to deduct the fair market value of the Margoline building which he donated to the Mahwah Volunteer Fire Department for use in its fire drills. In 1968 the building was at least 40 years old, and had been partially destroyed by a fire in 1967 before its use by the fire department. The condition of the building after the fire was such that it could not be rented without renovation, and it was about to be condemned by municipal authorities for its unsafe condition.[/FONT]
[FONT=&quot]Since the land had risen in value to the point where it was far more valuable than the building, the petitioner decided not to restore the building after it was damaged by fire. Instead, he first collected $5,914.05 in fire insurance proceeds for the damage and then arranged for the building's use for fire drills and the testing of new fire equipment by the municipal fire department. As a result, the Margolin building was completely razed by three fire drills in 1968. After the petitioner removed the remaining debris, pushed over the rest of the foundation and chimney and covered the land, he was in possession of valuable land finally cleared of its 40-year old, two-story structure and more marketable than before.[/FONT]
[FONT=&quot]The testimony of the municipal fire chief indicated it is only by similar donations of buildings for use in fire drills that the volunteers in this rural area are able to test their new equipment and train new staff members under controlled conditions. Petitioner testified that in the past he had donated similar old buildings to other neighboring municipalities for use by their volunteer fire departments in their training and testing of equipment.[/FONT]
[FONT=&quot]Under the provisions of section 170(c)(1) of the Code there is allowed a deduction for a charitable contribution to or for the use of a political subdivision of a State, but only if the contribution or gift is made for exclusively public purposes. Contributions or gifts to a volunteer fire department are deductible under section 170(c)(1) on the ground that the volunteer fire department relieves a political subdivision of the burden of a function normally performed by a municipality. See I. T. 4030, 1950-2 C. B. 23, revoking I. T. 1867, II-2 C. B. 155. See also Roy C. McKenna [ Dec. 14,743], 5 T. C. 712 (1945); Isabella M. Sheldon [ Dec. 15,037], 6 T. C. 510 (1946). The donated building here was used exclusively for a public purpose.[/FONT]
[FONT=&quot]Respondent contends that the arrangement whereby petitioner permitted the Mahwah Volunteer Fire Department to conduct fire drills on the Margolin building does not qualify as a charitable contribution within the intendment of section 170. He argues that when faced with the impending condemnation of the building, the petitioner had no desire to rebuild and therefore donated it with the expectation that its demolition would increase the value of the land and make the property easier to convert to a more productive use.[/FONT]
[FONT=&quot]There is no doubt that petitioner's donation of the fire-damaged Margolin building resulted in a clearer tract of valuable land which he could market far more easily than before the demolition. There is also no doubt that petitioner was somewhat motivated in his donation by a desire to have the building burned to the ground by the volunteer fire department.[/FONT]
[FONT=&quot]Respondent argues that where the motivation for petitioner's actions does not appear to be from a ?detached and disinterested generosity,? and where evidence indicates that the primary motive for a contribution is to obtain a direct or indirect benefit by enhancing the value of his remaining property, then a charitable deduction for such a contribution should be denied. Commissioner v. Duberstein [ 60-2 USTC ?9515], 363 U. S. 278 (1960); Larry G. Sutton [ Dec. 31,075], 57 T. C. 239 (1971). Similarly, if a transfer is made with the expectation of receiving something in return as a quid pro quo for the transfer, respondent urges that a charitable deduction should be denied. Singer Company v. United States [ 71-2 USTC ?9685], 449 F. 2d 413 (Ct. Cl. 1971). Respondent correctly states the tests developed by the Duberstein, Sutton and Singer cases in determining whether a claimed charitable deduction will be allowed.[/FONT]
[FONT=&quot]This Court has often held that a charitable gift must proceed from affection, respect, admiration, charity or like impulses, rather than from either the incentive of anticipated benefit beyond the satisfaction flowing from the performance of a generous act, or the constraining force of any moral or legal duty. Rainer Companies, Inc. [ Dec. 32,182], 61 T. C. ? (1973); Charles O. Grinslade [ Dec. 31,823], 59 T. C. 566 (1973); and Harold E. Wolfe [ Dec. 30,323], 54 T. C. 1707 (1970).[/FONT]
[FONT=&quot]The ascertainment of a donor's subjective intent is frequently difficult to determine. Harold E. Wolfe, supra at 1715. The intent qualifying for a claimed charitable deduction has been found lacking in several situations, namely, where a manufacturer enlarged the future potential market for his product by allowing sizable discounts to a charitable organization, Singer Company v. United States, supra; where a taxpayer dedicated property for a public road in return for favorable zoning, public access and street frontage, Stubbs v. United States [ 70-2 USTC ?9468], 428 F. 2d 885 (C. A. 9, 1970); where land was given to a city under economic duress and threatened legal compulsion, United States v. Transamerica Corporation [ 68-1 USTC ?9279], 392 F. 2d 522 (C. A. 9, 1968); where taxpayers made payments to a hospital in order to obtain the right to practice as staff members thereof, S. M. Howard [ Dec. 25,975], 39 T. C. 833 (1963); where parents donated to an educational organization part of the cost of furnishing instruction to their children, Harold DeJong [ Dec. 24,997], 36 T. C. 896 (1961), affd. [ 62-2 USTC ?9794] 309 F. 2d 373 (C. A. 9, 1962); where a subdivider benefited from the existence of schools and recreational facilities on land he transferred in compliance with county zoning requirements, Jordon Perlmutter [ Dec. 27,665], 45 T. C. 311 (1965); where a subsidiary corporation transferred all its equity in bonds to its parent charitable corporation, Crosby Valve & Gage Co. [ Dec. 28,081], 46 T. C. 641 (1966), affd. [ 67-2 USTC ?9529] 380 F. 2d 146 (C. A. 1, 1967), certiorari denied 389 U. S. 976 (1967); where residents transferred their interest in a water and sewer system to their own village, Harold E. Wolfe, supra; where a resident conveyed to a city an easement over a strip of his land for use in widening an adjoining street, thereby enhancing his remaining property, Larry G. Sutton, supra; where petitioners conveyed land in return for substantial cash, other property, dismissal of condemnation suits and a zoning variance, Charles O. Grinslade, supra; and where a company donated a free stadium as an inducement to a city for the purchase of the land thereunder from the taxpayer, Rainier Companies, Inc., supra.[/FONT]
[FONT=&quot]In each of the above-cited cases a quid pro quo flowed back to the donor from the exempt organization donee which certainly exceeded the satisfaction which flows from the performance of a generous act. However, as noted by the Court of Claims in the Singer case, there are situations where the benefits of a charitable contribution inuring to the donor are incidental to the much greater benefits inuring to the general public from the donation. When this occurs, the small benefit to the donor does not destroy his right to a charitable contribution deduction. Such incidental, and therefore not disqualifying, benefits which may accrue to a donor within the intendment of section 170(c)(1) have included situations where the donor sought the development and maintenance of a favorable public image in the eyes of the donee organization, Singer Company v. United States, supra at 424; where the donors benefited from a widened street and extended sewer lines, Toole v. Tomlinson, [ 63-1 USTC ?9267] (M. D. Fla. 1963); where the taxpayer wanted to develop its business in a new city and create favorable relations with the community, Citizens & Southern National Bank of S. C. v. United States [ 65-2 USTC ?9618], 243 F. Supp. 900 (W. D. S. C. 1965); where the removal of railroad traffic through a city benefited merchants and owners of property in the central shopping area, Rev. Rul. 67-446, 1967-2 C. B. 119; and where the provision of public parking for the general public benefited the merchants who contributed toward the facility in the business area of the city, Rev. Rul. 69-90, 1969-1 C. B. 63.[/FONT]
[FONT=&quot]In each of these above-cited cases the quid pro quo which flowed back to the donor did not disqualify the claimed charitable contribution deduction. Thus, where the primary benefit inures to the general public with only lesser and incidental benefits flowing back to the donor, then a charitable deduction will be allowed.[/FONT]
[FONT=&quot]While we are confronted here with an exceedingly close question, we conclude under these particular circumstances that the benefit flowing back to petitioner, consisting of clearer land, was far less than the greater benefit flowing to the volunteer fire department's training and equipment testing operations. The Margolin building, even after razing, still was not completely cleared from the land. Petitioner needed to remove the debris, demolish the foundation and chimney and cover the land before he could market the property. We think the petitioner benefited only incidentally from the demolition of the building and that the community was primarily benefited in its fire control and prevention operations. Consequently, on balance, we hold that the petitioner is entitled to a charitable contribution deduction.[/FONT]
[FONT=&quot]Having reached this conclusion, we must decide the amount of the deduction to which the petitioner is entitled. Respondent contends that the petitioner donated only the use of the building rather than the building itself; and that the petitioner has failed to establish a marketable value for the privilege of using the building for fire drills. Where a charitable contribution is made in property other than money, the allowable deduction is measured by the fair market value of the property at the time of the contribution. Section 1.170-1(c)(1), Income Tax Regs.; John G. Allen [ Dec. 31,017], 57 T. C. 12 (1971).[/FONT]
[FONT=&quot]Petitioner contends that the fair market value of the Margolin building when donated was $22,585.95. His selected figure is closely related to testimony regarding the reproduction cost for the Margolin building. Respondent claims these costs bear little, if any, relation to the actual fair market value of the building, which was poorly maintained and badly fire-damaged, when donated. We agree.[/FONT]
[FONT=&quot]The question as to fair market value is, of course, one of fact. It may be predicated upon expert testimony and more generally on the record as a whole. Estate of Alexia DuPont Ortiz DeBie [ Dec. 30,900], 56 T. C. 876, 894 (1971); Philip Kaplan [ Dec. 27,248], 43 T. C. 663 (1965); Mattie Fair [ Dec. 22,269], 27 T. C. 866 (1957); Colonial Fabrics v. Commissioner [ 53-1 USTC ?9208], 202 F. 2d 105 (C. A. 2, 1953), affirming a Memorandum Opinion of this Court [ Dec. 18,096(M)]. All factors bearing on value are relevant, including the cost, selling price, sales of comparable properties, the present condition of the property, opinion evidence and market conditions.[/FONT]
[FONT=&quot]Using our best judgment, based upon careful consideration of all the evidence herein, we conclude, as reflected in our findings of fact, that the fair market value of the Margolin building when donated was $12,835.95. This amount represents the value ($18,750) of the building for insurance loss purposes less the amount ($5,914.05) of insurance proceeds recovered. We need not choose here between the value of the donated use of the building and its fair market value in its damaged condition because in these circumstances we find they are the same. Cf. Estate of Philip A. Carroll [ Dec. 25,659], 38 T. C. (1962). Consequently, we hold that the petitioner is entitled to a charitable contribution deduction of $12,835.95. In view of this conclusion, we find it unnecessary to consider the petitioner's alternative contention that he is entitled to either an abandonment or demolition loss equal to the adjusted basis in the building, which we have already determined was zero by the end of 1967.[/FONT]