People give us bikes, and we sell them. This is our main income.
Should we be treating this/reporting this as related business income or as a donation (realized FMV of an in-kind donation)? What do you guys do?
We have a fiscal agent. Let's say the answer does not affect their public support test.
Clarification: I don't mean anything to do with sales taxes, which we pay on everything we sell. I mean, is this effectively a (cash) donation? Would it be evidence of public support for the IRS?
On May 23, 2015, at 10:17 AM, Martin, Eric Vance evmartin@indiana.edu wrote:
People give us bikes, and we sell them. This is our main income.
Should we be treating this/reporting this as related business income or as a donation (realized FMV of an in-kind donation)? What do you guys do?
We have a fiscal agent. Let's say the answer does not affect their public support test.
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Assuming that you're run under a nonprofit, I think that if people give you bikes, those are donations. If people buy the bikes, I think that's a donation as well and I'm not sure they have to pay taxes. I would call the IRS to confirm. On May 23, 2015 7:33 AM, "Martin, Eric Vance" evmartin@indiana.edu wrote:
Clarification: I don't mean anything to do with sales taxes, which we pay on everything we sell. I mean, is this effectively a (cash) donation? Would it be evidence of public support for the IRS?
On May 23, 2015, at 10:17 AM, Martin, Eric Vance evmartin@indiana.edu
wrote:
People give us bikes, and we sell them. This is our main income.
Should we be treating this/reporting this as related business income or
as a donation (realized FMV of an in-kind donation)? What do you guys do?
We have a fiscal agent. Let's say the answer does not affect their
public support test.
The ThinkTank mailing List <a href="
http://lists.bikecollectives.org/options.cgi/thethinktank-bikecollectives.or... from this list</a>
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Hi, Bicycles that are sold, even if donated, are subject to sales tax in every state. I know of a non-profit reuse organization that ended up owing 150k for not paying sales tax.
In NYS, reuse companies are required to get a special commercial license. Non-profits are exempt from this requirement. I'm not sure how this is applied in other states.
For accounting purposes, second hand bicycles are not assigned a dollar value in the end of year inventory: only items that we paid for with the intent for resale.
Karen Recycle-A-Bicycle
On Fri, Jun 5, 2015 at 11:56 AM, Angel York aniola@gmail.com wrote:
Assuming that you're run under a nonprofit, I think that if people give you bikes, those are donations. If people buy the bikes, I think that's a donation as well and I'm not sure they have to pay taxes. I would call the IRS to confirm. On May 23, 2015 7:33 AM, "Martin, Eric Vance" evmartin@indiana.edu wrote:
Clarification: I don't mean anything to do with sales taxes, which we pay on everything we sell. I mean, is this effectively a (cash) donation? Would it be evidence of public support for the IRS?
On May 23, 2015, at 10:17 AM, Martin, Eric Vance evmartin@indiana.edu
wrote:
People give us bikes, and we sell them. This is our main income.
Should we be treating this/reporting this as related business income or
as a donation (realized FMV of an in-kind donation)? What do you guys do?
We have a fiscal agent. Let's say the answer does not affect their
public support test.
The ThinkTank mailing List <a href="
http://lists.bikecollectives.org/options.cgi/thethinktank-bikecollectives.or... from this list</a>
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Here in Canada we don't have to collect or remit tax as long as our revenues stay below $50,000. The minute you go over that, even for only one year, means collecting and remitting forever after.
Mark Rehder - Coordinator re-Cycles Community Bike Shop http://re-cycles.ca
On 2015-06-05, at 1:38 PM, Karen Overton wrote:
Hi, Bicycles that are sold, even if donated, are subject to sales tax in every state. I know of a non-profit reuse organization that ended up owing 150k for not paying sales tax.
In NYS, reuse companies are required to get a special commercial license. Non-profits are exempt from this requirement. I'm not sure how this is applied in other states.
For accounting purposes, second hand bicycles are not assigned a dollar value in the end of year inventory: only items that we paid for with the intent for resale.
Karen Recycle-A-Bicycle
On Fri, Jun 5, 2015 at 11:56 AM, Angel York aniola@gmail.com wrote: Assuming that you're run under a nonprofit, I think that if people give you bikes, those are donations. If people buy the bikes, I think that's a donation as well and I'm not sure they have to pay taxes. I would call the IRS to confirm.
On May 23, 2015 7:33 AM, "Martin, Eric Vance" evmartin@indiana.edu wrote: Clarification: I don't mean anything to do with sales taxes, which we pay on everything we sell. I mean, is this effectively a (cash) donation? Would it be evidence of public support for the IRS?
On May 23, 2015, at 10:17 AM, Martin, Eric Vance evmartin@indiana.edu wrote:
People give us bikes, and we sell them. This is our main income.
Should we be treating this/reporting this as related business income or as a donation (realized FMV of an in-kind donation)? What do you guys do?
We have a fiscal agent. Let's say the answer does not affect their public support test.
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Thanks everyone for responding.
My question is whether, in the U.S., you call the sale value of donated bicycles a donation or business income.
For example, if the former, it could contribute to meeting a public support test.
Of course we pay taxes on sales.
On Jun 5, 2015, at 11:56 AM, Angel York <aniola@gmail.commailto:aniola@gmail.com> wrote:
Assuming that you're run under a nonprofit, I think that if people give you bikes, those are donations. If people buy the bikes, I think that's a donation as well and I'm not sure they have to pay taxes. I would call the IRS to confirm.
On May 23, 2015 7:33 AM, "Martin, Eric Vance" <evmartin@indiana.edumailto:evmartin@indiana.edu> wrote: Clarification: I don't mean anything to do with sales taxes, which we pay on everything we sell. I mean, is this effectively a (cash) donation? Would it be evidence of public support for the IRS?
On May 23, 2015, at 10:17 AM, Martin, Eric Vance <evmartin@indiana.edumailto:evmartin@indiana.edu> wrote:
People give us bikes, and we sell them. This is our main income.
Should we be treating this/reporting this as related business income or as a donation (realized FMV of an in-kind donation)? What do you guys do?
We have a fiscal agent. Let's say the answer does not affect their public support test.
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Hi Martin, The sale of a donated bicycle is earned income, not a donation.
Karen
On Fri, Jun 5, 2015 at 2:11 PM, Martin, Eric Vance evmartin@indiana.edu wrote:
Thanks everyone for responding.
My question is whether, in the U.S., you call the sale value of donated bicycles a donation or business income.
For example, if the former, it could contribute to meeting a public support test.
Of course we pay taxes on sales.
On Jun 5, 2015, at 11:56 AM, Angel York aniola@gmail.com wrote:
Assuming that you're run under a nonprofit, I think that if people give you bikes, those are donations. If people buy the bikes, I think that's a donation as well and I'm not sure they have to pay taxes. I would call the IRS to confirm. On May 23, 2015 7:33 AM, "Martin, Eric Vance" evmartin@indiana.edu wrote:
Clarification: I don't mean anything to do with sales taxes, which we pay on everything we sell. I mean, is this effectively a (cash) donation? Would it be evidence of public support for the IRS?
On May 23, 2015, at 10:17 AM, Martin, Eric Vance evmartin@indiana.edu
wrote:
People give us bikes, and we sell them. This is our main income.
Should we be treating this/reporting this as related business income or
as a donation (realized FMV of an in-kind donation)? What do you guys do?
We have a fiscal agent. Let's say the answer does not affect their
public support test.
The ThinkTank mailing List <a href="
http://lists.bikecollectives.org/options.cgi/thethinktank-bikecollectives.or... from this list</a>
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At the Bicicocina in Los Angeles we take care to separate new parts (sales) from donations associated with using old donated parts/frames. We collect sales tax on these new parts, not on the donations for working with used parts / bicycles.
So, someone comes in and needs a new tube and a used crank. We'll charge them $5 for the tube, and suggest a $3 donation for the crank. We pay sales tax only on the $5 for the tube, and the $3 (or whatever the client agrees to donate) is a non-taxed donation.
We treat donated frames, aka project bikes, the same way. Donations suggested for a project bike are typically between $50-$150. It's worth noting that our project bikes are ineed *projects*. Clients typically have to work 4-10 hours to get them in safe working condition. It's pretty rare that you can just show up and find a 100% working bike.
I acknowledged that there is some careful language around all of this, but it can actually be a helpful thing to communicate to our clients given that we don't typically turn anybody away for lack of funds. (though people who come in repeatedly needing a "free bike" are effectively turned away if we suspect they are just selling them.)
M
On Fri, Jun 5, 2015 at 11:11 AM, Martin, Eric Vance evmartin@indiana.edu wrote:
Thanks everyone for responding.
My question is whether, in the U.S., you call the sale value of donated bicycles a donation or business income.
For example, if the former, it could contribute to meeting a public support test.
Of course we pay taxes on sales.
On Jun 5, 2015, at 11:56 AM, Angel York aniola@gmail.com wrote:
Assuming that you're run under a nonprofit, I think that if people give you bikes, those are donations. If people buy the bikes, I think that's a donation as well and I'm not sure they have to pay taxes. I would call the IRS to confirm. On May 23, 2015 7:33 AM, "Martin, Eric Vance" evmartin@indiana.edu wrote:
Clarification: I don't mean anything to do with sales taxes, which we pay on everything we sell. I mean, is this effectively a (cash) donation? Would it be evidence of public support for the IRS?
On May 23, 2015, at 10:17 AM, Martin, Eric Vance evmartin@indiana.edu
wrote:
People give us bikes, and we sell them. This is our main income.
Should we be treating this/reporting this as related business income or
as a donation (realized FMV of an in-kind donation)? What do you guys do?
We have a fiscal agent. Let's say the answer does not affect their
public support test.
The ThinkTank mailing List <a href="
http://lists.bikecollectives.org/options.cgi/thethinktank-bikecollectives.or... from this list</a>
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Hi Michael, Recycle-A-Bicycle's accountant has informed us that income on all sales is required because it is a transaction of cash for goods, whether used of new.
Karen
On Fri, Jun 5, 2015 at 2:50 PM, Michael Kirk michael.john.kirk@gmail.com wrote:
At the Bicicocina in Los Angeles we take care to separate new parts (sales) from donations associated with using old donated parts/frames. We collect sales tax on these new parts, not on the donations for working with used parts / bicycles.
So, someone comes in and needs a new tube and a used crank. We'll charge them $5 for the tube, and suggest a $3 donation for the crank. We pay sales tax only on the $5 for the tube, and the $3 (or whatever the client agrees to donate) is a non-taxed donation.
We treat donated frames, aka project bikes, the same way. Donations suggested for a project bike are typically between $50-$150. It's worth noting that our project bikes are ineed *projects*. Clients typically have to work 4-10 hours to get them in safe working condition. It's pretty rare that you can just show up and find a 100% working bike.
I acknowledged that there is some careful language around all of this, but it can actually be a helpful thing to communicate to our clients given that we don't typically turn anybody away for lack of funds. (though people who come in repeatedly needing a "free bike" are effectively turned away if we suspect they are just selling them.)
M
On Fri, Jun 5, 2015 at 11:11 AM, Martin, Eric Vance evmartin@indiana.edu wrote:
Thanks everyone for responding.
My question is whether, in the U.S., you call the sale value of donated bicycles a donation or business income.
For example, if the former, it could contribute to meeting a public support test.
Of course we pay taxes on sales.
On Jun 5, 2015, at 11:56 AM, Angel York aniola@gmail.com wrote:
Assuming that you're run under a nonprofit, I think that if people give you bikes, those are donations. If people buy the bikes, I think that's a donation as well and I'm not sure they have to pay taxes. I would call the IRS to confirm. On May 23, 2015 7:33 AM, "Martin, Eric Vance" evmartin@indiana.edu wrote:
Clarification: I don't mean anything to do with sales taxes, which we pay on everything we sell. I mean, is this effectively a (cash) donation? Would it be evidence of public support for the IRS?
On May 23, 2015, at 10:17 AM, Martin, Eric Vance evmartin@indiana.edu
wrote:
People give us bikes, and we sell them. This is our main income.
Should we be treating this/reporting this as related business income
or as a donation (realized FMV of an in-kind donation)? What do you guys do?
We have a fiscal agent. Let's say the answer does not affect their
public support test.
The ThinkTank mailing List <a href="
http://lists.bikecollectives.org/options.cgi/thethinktank-bikecollectives.or... from this list</a>
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I agree with Karen
We submit taxes on all sales ( used and new parts and accessories, and used bikes that are refurbished or ‘as-is’ project bikes)
Deb
Deb Salls
Executive Director
Bike Works Program Classrooms and Offices
3715 S. Hudson Ave Suite #111 (Lower level)
Seattle, WA 98118
206-695-2522 Main line
206-695-2607 Direct line
Bike Works Community Bike Shop 3709 S. Ferdinand St. Seattle, WA 98118 206-725-8867
http://www.bikeworks.org/ http://www.bikeworks.org
Follow us on http://www.facebook.com/home.php#%21/BikeWorksSeattle Facebook and http://twitter.com/bikeworks206 Twitter
"Building sustainable communities by educating youth and promoting bicycling."
From: Thethinktank [mailto:thethinktank-bounces@lists.bikecollectives.org] On Behalf Of Karen Overton Sent: Friday, June 05, 2015 11:56 AM To: The Think Tank Subject: Re: [TheThinkTank] Accounting for sales of donated bikes
Hi Michael,
Recycle-A-Bicycle's accountant has informed us that income on all sales is required because it is a transaction of cash for goods, whether used of new.
Karen
On Fri, Jun 5, 2015 at 2:50 PM, Michael Kirk michael.john.kirk@gmail.com wrote:
At the Bicicocina in Los Angeles we take care to separate new parts (sales) from donations associated with using old donated parts/frames. We collect sales tax on these new parts, not on the donations for working with used parts / bicycles.
So, someone comes in and needs a new tube and a used crank. We'll charge them $5 for the tube, and suggest a $3 donation for the crank. We pay sales tax only on the $5 for the tube, and the $3 (or whatever the client agrees to donate) is a non-taxed donation.
We treat donated frames, aka project bikes, the same way. Donations suggested for a project bike are typically between $50-$150. It's worth noting that our project bikes are ineed *projects*. Clients typically have to work 4-10 hours to get them in safe working condition. It's pretty rare that you can just show up and find a 100% working bike.
I acknowledged that there is some careful language around all of this, but it can actually be a helpful thing to communicate to our clients given that we don't typically turn anybody away for lack of funds. (though people who come in repeatedly needing a "free bike" are effectively turned away if we suspect they are just selling them.)
M
On Fri, Jun 5, 2015 at 11:11 AM, Martin, Eric Vance evmartin@indiana.edu wrote:
Thanks everyone for responding.
My question is whether, in the U.S., you call the sale value of donated bicycles a donation or business income.
For example, if the former, it could contribute to meeting a public support test.
Of course we pay taxes on sales.
On Jun 5, 2015, at 11:56 AM, Angel York aniola@gmail.com wrote:
Assuming that you're run under a nonprofit, I think that if people give you bikes, those are donations. If people buy the bikes, I think that's a donation as well and I'm not sure they have to pay taxes. I would call the IRS to confirm.
On May 23, 2015 7:33 AM, "Martin, Eric Vance" evmartin@indiana.edu wrote:
Clarification: I don't mean anything to do with sales taxes, which we pay on everything we sell. I mean, is this effectively a (cash) donation? Would it be evidence of public support for the IRS?
On May 23, 2015, at 10:17 AM, Martin, Eric Vance evmartin@indiana.edu wrote:
People give us bikes, and we sell them. This is our main income.
Should we be treating this/reporting this as related business income or as a donation (realized FMV of an in-kind donation)? What do you guys do?
We have a fiscal agent. Let's say the answer does not affect their public support test.
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For those inquiring or otherwise interested...
Here's how it can be viewed from an accounting standpoint. Mind you, I am not an accountant. I would strongly recommend you consult with or hire a certified public accountant (CPA in the US), or a tax attorney, preferably one specializing in non-profits, if that is the form of your entity.
In any case, this is how I see the donation/gift of equipment from an accounting point of view. Regardless of being a non-profit [501c3 in the US, Registered Charity in Canada], or another form of ownership, generally this is how it would be handled in dual entry accounting following generally-accepted accounting principles (GAPP).
A donation/gift of equipment is made to the organization -- Assuming the bike is worth $100, you would -- 1a. Put the bike in a secure location within your facility, Debit [increase $100] Asset category *Inventory - Bikes* 1b Record the donation, Credit [increase $100] Income/Revenue category *In-Kind (non-cash) Donations*/Gifts (the latter if you are not a charity)
When the equipment is sold by the organization, say at $150 -- 2a. Accept cash for the bike, Debit [Increase $150, $157.50 with sales tax*] Asset category *Cash in Bank* 2b. If sales tax is collected in step 2a, Credit [Increase $7.50] Liability category *Sales Tax Payable, *at the time of the sale, if it applies to such a sale in your area. 2c. Record the sale, Credit [increase $150] in Revenue category *Gross Sales* 2d. Record the cost of the sale, Debit [increase $100] Sales Revenue sub-category *Cost of Good Sold* 2e. Hand over the bike to the buyer, and remove the item from inventory, Credit [decrease $100] Asset category *Inventory - Bikes* 2f. Note: Since Gross Sales of $150 is reduced by the Cost of the Sale of $100, the accounting process would clarify your *Net Sale* amount as $50 (for informational purposes mainly).
Later, if 2b applies, pay your Sales Tax Payable Liabilities to the State/Province -- 3a. Pay from your checking account to the Gov't sales tax agency, Credit [decrease $7.50] Asset category of *Cash in Bank* 3b. Remove the tax liability of the transaction, Debit [decrease $7.50] Liability category *Sales Tax Payable*
This is the general accounting activity for the donations/gifting of the equipment, and its sale, for any kind of organization. Other accounting categories may come into play if sales discounts, donor premiums, or the like, are a part of either the donation or the sale.
For non-profits, assuming this sale is part of your purpose, and therefore an exempt activity according to the IRS (or the CRA), then the net sale amount of $50 would not be taxable. If it is not an exempt activity, it could be considered non-related business income and it might be taxable. Might because, non-profits in the US are allowed a certain portion of non-related business income (outside of their exempt purpose) before it is considered taxable. Above that portion, the non-related business income would then be taxed similar to profit making entities. It makes sense for the non-profit, if there is a continual stream of non-related business income (outside of their exempt purpose), to create a wholly-owned profit making subsidiary that can function and be taxed like other businesses and with the net profit (after taxes) support the non-profit to fulfill its exempt purposes.
Again, it is strongly recommended that you defer to the expertise of a certified public account or a tax attorney (preferably those specializing in non-profit/charity laws, taxes and the rules of accounting)
- assuming sales tax rate is 5%
I hope this clarifies things. Non-profits do record sales. Don't be fearful of recording them. Publications, media, subscriptions, apparel, etc. are normal sales for non-profits. Removing a bike from your inventory and accepting cash for it does not comprise a donation, it is a sale. This is normal for the types of orgs on this forum.
Cheers, to success, Clark Forden
On Fri, Jun 5, 2015 at 11:56 AM, Angel York aniola@gmail.com wrote:
Assuming that you're run under a nonprofit, I think that if people give you bikes, those are donations. If people buy the bikes, I think that's a donation as well and I'm not sure they have to pay taxes. I would call the IRS to confirm. On May 23, 2015 7:33 AM, "Martin, Eric Vance" evmartin@indiana.edu wrote:
Clarification: I don't mean anything to do with sales taxes, which we pay on everything we sell. I mean, is this effectively a (cash) donation? Would it be evidence of public support for the IRS?
On May 23, 2015, at 10:17 AM, Martin, Eric Vance evmartin@indiana.edu
wrote:
People give us bikes, and we sell them. This is our main income.
Should we be treating this/reporting this as related business income or
as a donation (realized FMV of an in-kind donation)? What do you guys do?
We have a fiscal agent. Let's say the answer does not affect their
public support test.
The ThinkTank mailing List <a href="
http://lists.bikecollectives.org/options.cgi/thethinktank-bikecollectives.or... from this list</a>
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Hi,
I have to respectively disagree with the advice Clark has provided.
In the US, the IRS clearly states that donors are responsible for placing a value on donated goods. Non-profits do not assign a value to donated bikes because it is a conflict of interest.
RAB has been advised by a CPA, that the full sale price of a refurbished bike is taxed, and that the full sale price of used parts is taxed. Our donated bikes and parts do not show up anywhere on the balance sheet. They only show up in the sale income in our profit and loss statement.
Karen
On Fri, Jun 5, 2015 at 8:53 PM, Clark Forden clarkforden@gmail.com wrote:
For those inquiring or otherwise interested...
Here's how it can be viewed from an accounting standpoint. Mind you, I am not an accountant. I would strongly recommend you consult with or hire a certified public accountant (CPA in the US), or a tax attorney, preferably one specializing in non-profits, if that is the form of your entity.
In any case, this is how I see the donation/gift of equipment from an accounting point of view. Regardless of being a non-profit [501c3 in the US, Registered Charity in Canada], or another form of ownership, generally this is how it would be handled in dual entry accounting following generally-accepted accounting principles (GAPP).
A donation/gift of equipment is made to the organization -- Assuming the bike is worth $100, you would -- 1a. Put the bike in a secure location within your facility, Debit [increase $100] Asset category *Inventory - Bikes* 1b Record the donation, Credit [increase $100] Income/Revenue category *In-Kind (non-cash) Donations*/Gifts (the latter if you are not a charity)
When the equipment is sold by the organization, say at $150 -- 2a. Accept cash for the bike, Debit [Increase $150, $157.50 with sales tax*] Asset category *Cash in Bank* 2b. If sales tax is collected in step 2a, Credit [Increase $7.50] Liability category *Sales Tax Payable, *at the time of the sale, if it applies to such a sale in your area. 2c. Record the sale, Credit [increase $150] in Revenue category *Gross Sales* 2d. Record the cost of the sale, Debit [increase $100] Sales Revenue sub-category *Cost of Good Sold* 2e. Hand over the bike to the buyer, and remove the item from inventory, Credit [decrease $100] Asset category *Inventory - Bikes* 2f. Note: Since Gross Sales of $150 is reduced by the Cost of the Sale of $100, the accounting process would clarify your *Net Sale* amount as $50 (for informational purposes mainly).
Later, if 2b applies, pay your Sales Tax Payable Liabilities to the State/Province -- 3a. Pay from your checking account to the Gov't sales tax agency, Credit [decrease $7.50] Asset category of *Cash in Bank* 3b. Remove the tax liability of the transaction, Debit [decrease $7.50] Liability category *Sales Tax Payable*
This is the general accounting activity for the donations/gifting of the equipment, and its sale, for any kind of organization. Other accounting categories may come into play if sales discounts, donor premiums, or the like, are a part of either the donation or the sale.
For non-profits, assuming this sale is part of your purpose, and therefore an exempt activity according to the IRS (or the CRA), then the net sale amount of $50 would not be taxable. If it is not an exempt activity, it could be considered non-related business income and it might be taxable. Might because, non-profits in the US are allowed a certain portion of non-related business income (outside of their exempt purpose) before it is considered taxable. Above that portion, the non-related business income would then be taxed similar to profit making entities. It makes sense for the non-profit, if there is a continual stream of non-related business income (outside of their exempt purpose), to create a wholly-owned profit making subsidiary that can function and be taxed like other businesses and with the net profit (after taxes) support the non-profit to fulfill its exempt purposes.
Again, it is strongly recommended that you defer to the expertise of a certified public account or a tax attorney (preferably those specializing in non-profit/charity laws, taxes and the rules of accounting)
- assuming sales tax rate is 5%
I hope this clarifies things. Non-profits do record sales. Don't be fearful of recording them. Publications, media, subscriptions, apparel, etc. are normal sales for non-profits. Removing a bike from your inventory and accepting cash for it does not comprise a donation, it is a sale. This is normal for the types of orgs on this forum.
Cheers, to success, Clark Forden
On Fri, Jun 5, 2015 at 11:56 AM, Angel York aniola@gmail.com wrote:
Assuming that you're run under a nonprofit, I think that if people give you bikes, those are donations. If people buy the bikes, I think that's a donation as well and I'm not sure they have to pay taxes. I would call the IRS to confirm. On May 23, 2015 7:33 AM, "Martin, Eric Vance" evmartin@indiana.edu wrote:
Clarification: I don't mean anything to do with sales taxes, which we pay on everything we sell. I mean, is this effectively a (cash) donation? Would it be evidence of public support for the IRS?
On May 23, 2015, at 10:17 AM, Martin, Eric Vance evmartin@indiana.edu
wrote:
People give us bikes, and we sell them. This is our main income.
Should we be treating this/reporting this as related business income
or as a donation (realized FMV of an in-kind donation)? What do you guys do?
We have a fiscal agent. Let's say the answer does not affect their
public support test.
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participants (7)
-
Angel York -
Clark Forden -
Deb Salls -
Karen Overton -
Mark Rehder -
Martin, Eric Vance -
Michael Kirk