Changing Domicile For Tax Purposes Is Beneficial If Done Correctly, Day Pitney Institutional Investor Team Represents a State Pension Fund in $150 Million Investment into a Private Equity Fund, Day Pitney Institutional Investor Team Represents a State Pension Fund in $1 Billion Investment in Fund of One, Scott Brian Clark Appointed to Bloomberg State Tax Advisory Board, Day Pitney Names Real Estate, Environmental Co-Chairs in NJ, Coffey, Gianetti Named Co-Chairs of Day Pitney Real Estate and Environmental Group, Day Pitney Names New Co-Chairs of Real Estate and Environmental Practice, Day Pitney Represents a Singapore-based Investment Management Firm in Forming Long/Short Fund, Day Pitney Represents a Singapore-based Investment Management Firm in Forming Healthcare Fund, Another Win for Dogs: Court Allows Emotional Support Dog Violating Association Pet Policy. But, inspect again before paying subsequent taxes (no use throwing away good money after bad. Thus, the TSC holder may reject attempted redemption payments when tendered by entities other than those listed above. All tax sale certificates and the foreclosure proceedings are deemed valid unless their validity is challenged by a defendant. The Supreme Court in Green Knight noted that the Tax Sale Law (N.J.S.A. These are just some of the reasons to consider consulting an attorney if you're facing a tax sale. 54:5-61 ) When the tax title certificate amount shall exceed the sum of two hundred ($200) dollars, the holder, upon redemption of the tax title shall be entitled to collect from the owner or other person having an interest in the lands an additional sum equal to two per cent of the amount so paid for the tax title certificate. Day Pitney Multistate Tax Practice Chair Scott Clark authored the article, "Changing Domicile For Tax Purposes Is Beneficial If Done Correctly," for Family Wealth Report. Self-help services may not be permitted in all states. As a seller of taxable goods or services, you are required to be registered with the New Jersey Division of Revenue and Enterprise Services. In addition, according to (Sec. _____ _____ Applicant' s Signature Date . ; exemption from taxation, Conveyance of land not suitable for forest park reservation to municipality; approval, Redemption of land from municipality; amount, Transfer to county for park purposes of lands acquired at tax sales, Redemption after transfer of lands to county for park purposes, Creation of joint municipal lien pool permitted, Operating plan filed by joint municipal lien pool, Indiana Petition for Waiver of Reinstatement Fee, CFR > Title 26 > Chapter I - Internal Revenue Service, Department of the Treasury, U.S. Code > Title 15 > Chapter 10B - State Taxation of Income From Interstate Commerce, U.S. Code > Title 26 - Internal Revenue Code, California Codes > Business and Professions Code > Division 1 > Chapter 8 - Dispute Resolution Programs, California Codes > Revenue and Taxation Code, Florida Regulations > Chapter 12-18 - Compensation for Tax Information, Florida Regulations > Division 12C - Corporate, Estate and Intangible Tax, Florida Statutes > Chapter 199 > Part I - Nonrecurring Tax, Florida Statutes > Chapter 218 > Part VI - Participation in Half-Cent Sales Tax Proceeds, Florida Statutes > Chapter 220 - Income Tax Code, Illinois Compiled Statutes > Chapter 35 > Collections And Refunds, Illinois Compiled Statutes > Chapter 35 > Exemptions, Missouri Laws > Chapter 14 - Collection of United States Revenue, Texas Labor Code Chapter 104 - Information Regarding Earned Income Tax Credit, You are late making a payment or commit some other default, triggering an increase to a penalty rate. 54:5-62 ) When the tax title certificate amount shall exceed the sum of $5,000, such additional sum shall be equal to 4% of such amount paid; and when the tax title certificate amount exceeds $10,000, such additional sum shall be equal to 6% of such amount paid. Many title companies thus believe it is advisable to add a notation to this effect to the title commitment in order to avoid future misunderstandings. Municipal Building. The certificate holder must wait a statutorily proscribed period after the date of the sale of the certificate to initiate a foreclosure action. The State of New Jersey Fee Schedule Fees subject to change Effective January 1, 2020 Union County Homeless Trust Fund increase from three dollars ($3.00) to five dollars ($5.00) for each document The following fee schedule applies to all services in the County Clerk's Office: What if I Purchased a Taxable Item or Service and Was Not Charged New Jersey Sales Tax? A third section (discussed above) permits redemption only by certain specified categories of persons. NJ Division of Taxation - Sales and Use Tax 54:5-32 ) the 'sale shall be made in fee to such person as will purchase the property, subject to redemption at the lowest rate of interest, but in no case in excess of 18% per annum. EkWHC.p-g(H\"p Kh7&3tdU`9. <>/ExtGState<>/XObject<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/Annots[ 20 0 R 21 0 R 22 0 R 35 0 R] /MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> In this article, you'll find details on property tax sale laws in New Jersey, with citations to statutes so you can learn more. What are the risks you are trying to avoid: unbuildable lots, crack houses, meth labs, environmentally challenged, wetlands, burnouts, demolished properties. The law exempts some sales and services from Sales Tax. New Jersey affords real. Please reference the Terms of Use and the Supplemental Terms for specific information related to your state. The amount in the Order. N.J.S.A. L.1943,c.149,s.3; amended 1947, c.415, s.1;1953, c.51, s.97;1997, c.190, s.12. In the case, Plaintiff purchased the tax sale certificate for a property in Vernon, New Jersey in 2017. Amount of redemption. Ly_$^3u8;5H!O0%0](Y8 0tU/Z3:Ao|q /,5;MKj,XLA -/KrGR =(jw'(KJ0#DX S`~M}D@oBd=Zf| >[6y [*R The New Jersey foreclosure process, too, takes a while, and you'll get notified before a foreclosure sale happens. Some TSC holders have demanded proof that redemption is being made as part of a bona fide transaction, requiring copies of closing statements and other closing-related documents before surrendering the TSC for cancellation. h4>MkumXZu2KndKv9r"}Sc>H0j1,Xm`C">aa-LGA?EdRY3uUS>bfK` J. N.J.S.A. 2020 New Jersey Revised Statutes - Justia Law In the present case the Appellate Division said: "In these transactions caveat emptor should be the rule.". Before you buy, you should stop and ask yourself if you're typical. On the positive side, having an escrow account saves you from having to come up with a large amount of money when tax bills, and perhaps other bills, are due. In other states, though, the redemption period happens before the sale. Resale Certificate for Non-New Jersey Sellers: Sales and Use Tax: 2017 Mar: ST-10: Motor Vehicle Sales and Use Tax Exemption Report: Sales and Use Tax: 2006 June: ST-10-A: 54:5-31). If you select the digital download version there will be no charge and you can immediately download the contents of your selection. Creating new precedent, on February 14, 2018, Judge Anne McDonnell, P.J. It is important to bear in mind that the amount necessary to redeem a privately-held TSC includes subsequently-accruing taxes paid by the holder thereof. 54:5-61 and (Sec. If privately held, the tax collector may neglect to include post-TSC taxes paid by the certificate holder. Then the holder records the tax sale certificate with the county clerk, who records the tax sale certificate as a lien against the property. The following is a list of counties located in the state of New Jersey. When assignments have not been recorded and served upon the tax collector, the tax collector and the municipality shall be held harmless for the payment of any redemption amounts to the holder of the tax sale certificate as appears on the records of the tax collector. 54:5-86, 54:5-87). xrFUyF+ZYvd- 1,k~{ . The investor then cross-moved for intervention and permission to redeem. Those answers are dealt with by the local judge in the County. Are There Any Exemptions to Paying Sales Tax? NJ Supreme Court Clarifies Investor Rights in Tax Sale Copyright CB Title Management Corp. 2008-2020 Terms and Conditions|Privacy Statement. Redemption is made at the office of the tax collector unless otherwise directed. PDF New Jersey Tax Certificate Process Please note: What is a Tax Sale? In New Jersey tax lien certificates are sold at each of the 566 municipal Tax Sales. Typically, the tax amount is based on a property's assessed value. !SB3FK+c4f-iZwD?/xx>|0}S(c [w3 kYltE.Oa!> ! . New Jersey's Tax Sale Law (N.J.S.A. If the USA (generally the IRS) has a lien, an alternate procedure must be followed. How courts and agencies interpret and apply the law can also change. Attached is the above-mentioned tax sale certificate on which this application is based and all other certificates of the same legal description, which are in my possession. Any and all further or additional assignments of the tax sale certificates shall be promptly recorded in the office of the county clerk or register of deeds, as the case may be, of the county wherein the real property is situate, and a photocopy of the recorded assignment shall be served upon the local tax collector by certified mail, return receipt requested. Note: If this is an OPRA request it must be sent to the Township Clerk. People who own real property have to pay property taxes. Tax delinquent properties are advertised in a local newspaper prior to the municipal tax sale. <> 54:5-31). (N.J. Stat. After the sale, the purchaser receives what's called a "certificate of sale." (N.J. Stat. You should receive a phone call or email within the next 24 hours. If your loan isn't escrowed and you fail to pay the taxes, your mortgage servicer will probably advance funds to pay them and then bill you for the cost. New Jersey's Tax Sale Law (N.J.S.A. Rather, instead of the OST, we apply for Final Judgment, submitting it to the Court with a Writ of Execution. New Jersey assesses taxes on the local (municipal) level. The municipal tax collector conducts the sale which allows third parties and the municipality itself to bid on the tax sale certificates (this is the document evidencing the taxes due and owing). Site Maintained by Division of Revenue and Enterprise Services, Governor Phil Murphy Lt. Once the time for redemption has expired, you obtain from the tax collector an Affidavit of Non-Redemption, where the collector certifies that the lien has not redeemed. 2022 Florida Annual Resale Certificate for Sales Tax This Certificate Expires on December 31, 2022 DR-13 R. 10/21 Business Name and Location Address Certificate Number By extending this certificate or the certificate number to a selling dealer to make eligible purchases of taxable property or services exempt from sales tax and discretionary . (N.J. Stat. Tax sale certificates can earn interest of up to 18 per cent, depending on the winning percentage bid at the auction. There was a problem with the submission. Google Translate is an online service for which the user pays nothing to obtain a purported language translation. Because the court stated that it was not announcing new rules of law, but rather construing existing statutes, its holdings in these cases are apparently applicable both retroactively and prospectively. endobj If the defendants in the foreclosure (i.e. But if the taxes aren't collected and paid through this kind of account, you must pay them directly. That's because the purchaser gets the right to foreclose to get title (ownership) of your home if you don't pay up. Get free summaries of new opinions delivered to your inbox! Although many municipalities do not understand, these statutes and ordinances do not apply to the holders of tax liens. Ann. (N.J. Stat. The user is on notice that neither the State of NJ site nor its operators review any of the services, information and/or content from anything that may be linked to the State of NJ site for any reason. If you've abandoned (that is, permanently moved out of) the home and the property meets specific criteria under state law, the foreclosure can start immediately after the tax lien sale. collects tax at the time of the sale and sends it to the State. The tax sale certificate holder must foreclose on the tax lien in order to become the owner of the property. The amount of the lien is the amount paid for the tax sale certificate plus interest (which normally accrues at a rate of 18%), costs and fees, including the certificate holders attorneys fees. Please refresh the page and try again, The servicer pays the taxes on your behalf through an. 2003, c. 210 (C. 55:19-83), any property that has not been legally occupied for a period of six months and which meets any one of the following additional criteria may be deemed to be abandoned property upon a determination by the public officer that: When you have a lien on an abandoned property, foreclose immediately you may be permitted entry for repairs. Hmg7P ;NE/X&1d[ SJ8{(SFZkB7VvM]"f z,,a3,\hGw]Wgp NJ Division of Taxation - New Jersey Sales and Use In recent years, a TSC industry has developed, with individuals and firms purchasing large quantities of certificates. Mar. 732-364-2500. Weve provided your information to lawyers in your area. Section 54:5-114.4a - Foreclosure on certain tax sale certificates; Section 54:5-114.5 - Extension of time for recording judgment; failure to record within time You must first complete an eviction, or the property must be voluntarily vacated. In New Jersey, you might lose your home if you don't pay the property taxes. Some examples of nontaxable goods and services are: Publication S&U-4 , New Jersey Sales Tax Guide, provides further information on Sales Tax. 54:5-86). If you are served with a foreclosure complaint or wish to pursue a claim on a tax sale certificate, please call us at (973) 890-0004 or e-mail us to see how we can assist you. 214 Fax: (609)-492-1109 taxoffice@beachhaven-nj.gov Tax Sale Certificate Redemption Request Form N.J.S.A. Thus, the TSC holder may reject attempted redemption payments when tendered by entities other than those listed above. Please tell us how they can get in touch for a free consultation. Copyright 2023 MH Sub I, LLC dba Nolo Self-help services may not be permitted in all states. The winning bidder must record the purchase of the tax lien certificate in the County Clerk's Office within 90 days of the purchase or risk losing their interest. A lien effectively makes the property act as collateral for the debt. New Jersey Tax Lien Certificates - New Jersey Tax Deeds One other note: Many lien holders take title to certificates in the name of a custodian or trustee. Each month, you'll have to pay approximately one-twelfth of the estimated annual cost of property taxesand perhaps other expenses, like insurancealong with your usual monthly payment of principal and interest. The interest rate is bid downward. The government uses the money that these taxes generate to pay for schools, public services, libraries, roads, parks, and the like. At any time before the sale, the taxpayer may pay the amount due plus interest and costs and stop the sale. 2018 and after; 2017 ; 2016 and prior ; ST-75: . Ann. of When the plaintiff (i.e. After 0%, then premiums are bid. Title Practice, 102.17 (4th Ed. Ann. View articles answer questions on tax lien certificates, tax deeds, and more. If you dont, you allow a lien senior in priority to your lien to be sold. -b-0 The tax sale certificate holder does not own the property, but merely has a lien against the property. Now you own the property. Foreclosure of Rental & Investment Property, Do Not Sell or Share My Personal Information. Shameless plug it is enormously helpful to you to use the services of an attorney and a title company who understands the tax foreclosure process when selling your REO. Many states give delinquent taxpayers the chance to pay off the amounts owed and keep the home. (When Use Tax is owed, often it is on products or services purchased out of state or online.) New Jersey Supreme Court Issues Important Decision on Waiver of a Teachers Tenure Rights, Update on Sanjuan v. School District of West New York Case: NJ Supreme Court Grants Certiorari in Education Employment Case, New Jersey Supreme Court Decision on Classification of Workers is a Cautionary Tale for Employers. Automobiles, furniture, carpeting, and meals bought in restaurants. What is the risk of purchasing a Tax Sale Certificate in New Jersey? Tax Lien University, Inc Many mortgages have a clause that gives the lender the ability to establish an escrow account basically at any time it chooses. Nevertheless, redemption statements prepared by tax collectors sometimes contain errors. Section 54:5-114.4 - Purchasers of tax sale certificates, liens; foreclosure, right of redemption, recording of final judgment; further, additional assignments recorded. Redeeming Your New Jersey Home: Right of Redemption | Nolo In New Jersey, you can pay subsequent taxes in each quarter that the owner does not, and add the amount paid as principal to your lien, earning 18% above $1500 (lien amount plus subsequent taxes), regardless of the interest rate on the certificate. The property has been determined to be a nuisance by the public officer in accordance with section 5 of P.L. We have 566 municipalities, each of which has its own tax sale. Lakewood, NJ 08701. Tax Sale Certificate Redemption - Cape May County, NJ It can be complicated, and will create a problem if it is not handled correctly.). New Jersey Tax Deed Sales New Jersey does have tax deed sales. This site is protected by reCAPTCHA and the Google, There is a newer version With almost no exception, we get rid of them after some brief litigation. Taxes continue to accrue on the property after the sale of the certificate. Sign up for our free summaries and get the latest delivered directly to you. If the interest is bid down to zero (0) percent, then a "premium," bid commences. For more information on Sales Tax exemptions, please see our publication S&U-6 (Sales Tax Administration). New Jersey Property Tax Sale Certificates and Foreclosures Provided by the Burlington County Clerk, Joanne Schwartz 07/07/2020 Filed map $55.00 per map copy of map - $15.00 large $10.00 small In NJ, all foreclosures are filed centrally in the Foreclosure Section of the Superior Court. The Company declares all information shared is true and accurate, and any claims made of actual earnings or examples of actual results can be verified upon request. 54:5-98. See N.J. We've helped 75 clients find attorneys today. Tax Certificate Sales - Miami-Dade County Pre-foreclosure notice to owners, mortgagees, holders of older tax liens. the property owners, mortgage holders, and lien holders) do nothing after they have been served with the complaint, the court will enter a judgment against the defendant. You can explore additional available newsletters here. One section of the Tax Sale Law prohibits one who has acquired an interest in land for a nominal consideration after the filing of the [TSC foreclosure] complaint from exercising the right of redemption (subject to certain exceptions). this Section. 54:5-32 ), Penalty Rate: 4% - 6% (Sec. Upon receipt of the cancelled certificate, the redemption funds will be released to the lien holder. . If you have a mortgage on your home, the loan servicer might collect money from you as part of the monthly mortgage payment to later pay the property taxes. In February 2023, Day Pitney represented a Singapore-based investment management firm in connection with the formation of an ERISA hardwired master-feeder fund structure focused on investing primarily in the Australian resources sector using a long/short investment approach. In short, an investor's entitlement to redeem is not forfeited because it failed to move to intervene prior to attempting redemption of the tax sale certificate, provided the investor meets the statutory prerequisite, inter alia, of a fair market value acquisition. When you buy items or services in New Jersey, you generally pay Sales Tax on each purchase. What is the risk of purchasing a Tax Sale Certificate in New Jersey? 54:5-32 ), Redemption Period: Two (2) years (Sec. N.J. Ct. R. 4:64 Download PDF As amended through April 5, 2023 Rule 4:64 - Foreclosure of Mortgages, Condominium Association Liens and Tax Sale Certificates Rule 4:64-1. Bidders have the option to pay these subsequent taxes; if they are not paid, a tax sale certificate will be sold at the next tax sale. The process was made more complex as a result of the decisions of the New Jersey Supreme Court in Simon v. Cronecker, 189 N.J. 304 (2007); Simon v. Rando, 189 N.J. 339 (2007); and Malinowski v. Jacobs, 189 N.J. 345 (2007). That means everyone except senior (newer) tax liens, and NJ Spill Act liens (bad). Because the face amount of a TSC is frequently much less that the value of the realty it encumbers, TSC purchasers seek to capitalize on their investment by successfully foreclosing the encumbered land and re-selling the same at a profit. Thus, the purchaser must successfully intervene in the suit (in accordance with Rule No. Be sure to cite the correct The court will eventually enter a judgment, which eliminates the right to redeem. 'TP:8~Vg,Ke0!n{B*+vo-\\0a@&K2f_6[U]?+h-G;B(q&gj+"v8%% _5|w|bM nS*l>F@*^z9w_%[2_x4 1 0 obj File the appropriate pleadings to get an Order Setting Time, Place and Amount for Redemption (OST). 54:5-54. Another section apparently requires a party acquiring an interest in the property after the foreclosure has begun to intervene in the suit in order to exercise the right of redemption. (N.J. Stat. [}4k8 hX g`NOb@R9K0QhOr-e{Xs Rn!g?_~SvZP.dDsC40 n_=Z!jW/iQzx @AtcpHX?N_!k;#Qy\EH7 \U^e|{s/K_R}"1-1 F{Do8E\`uh`Y8dUZ %PDF-1.7 The successful highest bidder then pays the outstanding taxes to the municipality and become the tax sale certificate holder. {uO .n?cI DUE PROCESS IS THE KEY. In New Jersey, the length of the redemption period depends on whether a third party was the winning bidder at the sale and whether the home is vacant. The user is on notice that neither the State of NJ site nor its operators review any of the services, information and/or content from anything that may be linked to the State of NJ site for any reason. Because a property tax lien has priority, if you lose your home through a tax sale process, mortgages get wiped out. Tax Sale Information | Willingboro Township, NJ Redemption of tax sale certificates [TSCs] can present difficulties for buyers and sellers, as well as for their attorneys and title companies. But if the taxes aren't collected and paid through this kind of account, you must pay them directly. Personal service can be difficult, but is always best. There is no OST issued. New Jersey Statutes 54:5-63.1. Excessive charges or fees charged by tax Definition - The sale of property to collect payment of delinquent tax or other Municipal Charges Inclusive of Taxes, interest, costs of sale, water, sewer, electric, Assessments for Improvements, demolitions, board ups, etc. After two (2) years, the tax lien certificate owner can initiate proceedings in Superior Court to foreclose on the property. Foreclosure Complaint, Uncontested Judgment Other Than In Rem Tax Foreclosures (a)Title Search; Certifications. Tax Collector : Township of Lakewood - Lakewood Township, New Jersey At the same time, others seek to turn the process to their advantage by purchasing such properties at a discount or by acquiring a lien or interest therein, so that they can exercise (or attempt to exercise) the right of redemption. info [at] taxlienuniversity.com Sign Purchases and Installation Services Sales and Use Tax Effective October 1, 2022. No Charge: Subordination Agreement: $30, $10, $10: Tax Sale Certificate: $30, $10: Tax Sale Certificate Municipal: $8: Termination of Lease: $30, $10, $10: Termination of Fine State (UCC) $25 . Purchasing the tax sale certificate is merely the first step. The right of redemption is limited to certain persons or entities (whether redemption occurs before or after the commencement of the foreclosure suit). Once registered, you must display your Certificate of Authority for Sales Tax (Form CA-1) at your business location. Requirements 1. (N.J. Stat. 54:5-58) 6. Note: there are statutes forcing lenders to register and to be liable for care of abandoned properties. The first step in the process is the tax sale. To find New Jersey's laws that discuss property tax lien certificate sales, go to Title 54, 54:5-1 through 54:5-137 of the New Jersey Statutes. So, for example, depending on the circumstances, nominal consideration may be $1.00 in one case and $10,000 in another. PDF I citizen I people l grants l - The Official Web Site for The State of If you're already facing a property tax sale in New Jersey and have questions (or need help redeeming your property), consider talking to a foreclosure, tax, or real estate lawyer. Statutes change, so checking them is always a good idea. This process is called "redeeming" the property. . Unprepared food for human consumption, clothing, certain professional and personal services, and real estate sales. What next? The loan servicer then pays the cost of the taxes and other escrow items on your behalf through the escrow account. 2021 by Tax Lien University, Inc. All rights reserved. The rate of tax is 6.625% on taxable sales occurring on or after January 1, 2018. You already receive all suggested Justia Opinion Summary Newsletters. In fact, the typical customer does not even finish the training videos. Section 54:5-63.1 - Excessive charges or fees charged by tax sale In order to recoup the value of unpaid property taxes, the statute requires that each municipality hold an annual tax sale of properties in arrears on their property taxes. At the auction, bidders bid down the interest rate that will be paid by the owner for continuing interest on the certificate amount. 2016) discusses issues relating to the redemption of TSCs. YtGa w+Ppt_? KB9a+a\P:sQlf&.pld\mt;gV]@ w l#t-uV.Bn`'c~M@(!J. This is your permit to collect Sales Tax and to use Sales Tax exemption certificates. The amount needed to redeem a municipally-held certificate includes unpaid subsequently-accruing taxes. Learn more about each county's individual tax sale process by clicking on the name of the county for which you are interested from the list below: Learn about buying tax lien certificates and tax deeds with this free training course. Under N.J.S.A 54:5-54 (as amended), redemption is restricted to: (1) the landowners or their heirs; (2) holders of prior TSCs; (3) mortgagees; or (4) occupants of the land. New Jersey assesses a 6.625% Sales Tax on sales of most tangible personal property, specified digital products, and certain services unless specifically exempt under New Jersey law. At the public auction, the property is sold (subject to the right of redemption) to the person who offers the lowest interest rate on the tax debt, which can't exceed 18%. The court further found that an investor could seek to redeem a tax sale certificate prior to intervening in the foreclosure matter and that failure to intervene first would not bar the investor from redeeming the tax sale certificate. Non-municipal tax sale certificate holders must provide thirty days written notice of their intention to foreclose before they can begin the foreclosure process on the certificate. Lawn maintenance, auto repair, snow removal, and telecommunications. The tax certificate represents a lien on unpaid real estate properties. The right of redemption is the right to pay off the debt and prevent the loss of the property. As suggested above, every effort must be made to ensure that the redemption statement is accurate. X|v1E?d7df~~oc={l_vgo?+G$'xxpfoh Q PBT3+afP/H;9>2Hn-~{~3~+T!^p'q;Jy UYB#x58_hd{?`77x;T- WhEAGN|&pn|9~&*QZ0HATo! By Robert W. Keyser.
Scarsdale Car Accident,
Best Dahlias For Show,
Evidence-based Practices Resource Center,
Articles T