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2contradiction
| action : The United Nations must have the power to propose and organize action without being hobbled by irrelevant issues. :
action : Recent federal action undermined the segregationist position. : | This example is False. | super_glue/wic |
0entailment
| two dogs , one with long brown fur , both dogs have their mouths open and teeth showing , one dogs tongue is hanging out .
There is a better than even chance that a dog is chasing a cat out their on the fields . | This example is valid. | probability_words_nli/usnli |
0entailment
| Chances are slight that Mary left the football. There is almost no chance that Bernhard is a swan. We believe that Julius is a frog.
Chances are slight that either Bernhard is a swan, or Mary left the football. | This example is invalid. | probability_words_nli/reasoning_1hop |
2contradiction
| It is improbable that Sandra took the football. It is probably the case that Julie is in the bedroom. It is probable that Daniel put down the milk. It is highly unlikely that if Julie is in the bedroom, and Sandra took the football, then Greg is a frog. There is little chance that if Julie is in the bedroom, or Sandra took the football, then Julius is yellow. It is almost certain that if Sandra took the football, or Julie is in the bedroom, then John moved to the garden.
It is probably not the case that julie is in the bedroom, or Daniel put down the milk. | This example is invalid. | probability_words_nli/reasoning_2hop |
0entailment
| Maternal employment or non parental child care are not an allegation of the findings from last Wednesday .
These findings are not an indictment of maternal employment or nonparental child care . | This example is non-contradiction. | robust_nli_li_ts |
0entailment
| Brazilian despair turns to anger as toll from Vale dam disaster hits 60
Brazil union says it urged Vale to move offices away from burst dam | This example is same_event. | hlgd |
2contradiction
| Mercy Lewis , known formally as Mercy Allen , was the child of Philip Lewis and Mary ( Cass ) Lewis .
Mercy Allen , formally known as Mercy Lewis , was the child of Philip Lewis and Mary ( Cass ) Lewis . | This example is paraphrase. | paws/labeled_final |
2contradiction
| As the Dauphin 's translator , Burkhard was sent as negotiator to the decimated Swiss in the hospital to offer them the chance of safe surrender and honorable conduct .
As the Dauphin 's translator , Burkhard was sent as negotiator to the decimated Swiss in the hospital to offer them the chance of honorable surrender and safe conduct . | This example is paraphrase. | paws/labeled_swap |
2contradiction
| What happens at fetal heart ultrasound?
What's the best time to do a fetal heart ultrasound? | This example is True. | medical_questions_pairs |
0entailment
| We yelled Harry hoarse. | This example is unacceptable. | glue/cola |
2contradiction
| is for the most part a useless movie , even with a great director at the helm . | This example is positive. | glue/sst2 |
0entailment
| Is it possible for one eye's vision to be temporarily blurry one day and normal the next day? | This example is valid question. | insincere-questions |
0entailment
| icici prudential fixed maturity plan series 63-3 year l-dividend half yearly fund: debt fund performance, charts & returns n tl;dr the best of rest is in this from wells fargo. click here for a detailed analysis. and on any stock to get more information. was one that i had been looking at it looks like it's going up as well. has an interesting yield curve with low volatility but high volatility. not cheap by market value so you may want some other funds if that's what you're after. there are plenty out there. can also buy these stocks through mutual funds. there's lots here. just make sure they're all good ones. not, then go back over them again. luck. -david m tepper (@davidm_teepper) managing director, tiaa-cref new york city exchange www.tiaascref.com. follow me at: or e-mail me: davetpenney1 @ gmail.com. my email address is: #more-2930 ... wired, accessed august 23, 2011 scientists have discovered how they could create superconducting material using simple magnets - team led scientists who made two years ago found ways around magnetic field lines into creating tiny particles called topological insulators created inside gold nanowiew able materials would be used across multiple times faster than current which will find way better conductors within 100 million kilometers long distance between them. order 10 micrometer were developed dr. peter j. michael l. he said last research center niversity researchers say first time nanosmossys such magnet size nanotube nano fiber wires should produce energy density nanosecond source says its own sources cost about 2 millimeters. examples second largest single wire thickness prof. r. makes ultra thin = 4 milli@@ | This example is ctrl. | TuringBench |
2contradiction
| What 's the Olympic motto ? | This example is NUM:ord. | trec |
2contradiction
| Zedd is Russian-German .
Anton Zaslavski ( ; born 2 September 1989 ) , better known by his stage name Zedd ( ) , is a Russian-German record producer , DJ , multi-instrumentalist and songwriter . | This example is REFUTES. | vitaminc/tals--vitaminc |
2contradiction
| What is that | This example is not-English. | hope_edi/english |
0entailment
| BREAKING: At least 10 killed in shooting at French satirical newspaper Charlie Hebdo, Paris prosecutor's office says. http://t.co/mnAeA7j7fY
@jayanthkumarak @cnni Sad sad day | This example is comment. | rumoureval_2019/RumourEval2019 |
0entailment
| Are you sure you are a girl? That wig on your legs say: I WANT TO BE A BOY | This example is hate_speech. | ethos/binary |
0entailment
| @user The irony is that those protesting about this kind of stuff are the Orwellian nightmare they think they’re fighting against. | This example is anger. | tweet_eval/emotion |
0entailment
| An Honest Article About Illegal Immigration By a Lefty?? Are Pigs Flying? - A miracle... | This example is non-hate. | tweet_eval/hate |
2contradiction
| @user lol how and what is a cthulhu ?? Funny autocorrect so helpful | This example is non_irony. | tweet_eval/irony |
0entailment
| @user @user @user @user That makes zero sense as you are conflating biogenic with non biogenic emission sources. | This example is non-offensive. | tweet_eval/offensive |
2contradiction
| I swear I'm going to every Monday wonders over Xmas possible | This example is negative. | tweet_eval/sentiment |
0entailment
| How dare you say my sexual preference is a choice, how dare you say dismembering my preborn isn't. #liberalism #SemST | This example is against. | tweet_eval/stance_abortion |
0entailment
| @user an hour? You need to buy better weed @user #weed #SemST | This example is none. | tweet_eval/stance_atheism |
2contradiction
| @user it's crazy. Oklahoma is bracing for more flooding rains (4th cycle this year) & Canada is burning. #SemST | This example is against. | tweet_eval/stance_climate |
2contradiction
| Feminists saying they are "atheists/skeptics" is quite a contradiction as they worship their own vulva. #GamerGate #SemST | This example is favor. | tweet_eval/stance_feminist |
2contradiction
| @user @user Hillary's New Campaign slogan is: HILLARY - NOTHING TO HIDE BUT THE TRUTH! #tcot #WakeUpAmerica #SemST | This example is favor. | tweet_eval/stance_hillary |
0entailment
| Happy Thanksgiving from 2 lil Indians #folsomturkeytrot #blessedbeyondmeasure @ Folsom Turkey Trot | This example is ❤. | tweet_eval/emoji |
0entailment
| Maybe invading Iran isn't the point.
Just maybe they are running out of ways to make us pee our pants in fear and maintain some support for staying in Iraq. | This example is maybe,. | discovery/discovery |
2contradiction
| so why have someone in jail for a year or two for a misdemeanor. | This example is Signal-non-understanding. | pragmeval/switchboard |
0entailment
| not not entirely modify it. | This example is Downplayer. | pragmeval/mrda |
2contradiction
| not feasible. | This example is experiential. | pragmeval/verifiability |
2contradiction
| vogue magazine's new offices are infested with rats
vogue's shiny new office has a big rat problem | This example is against. | pragmeval/emergent |
2contradiction
| by assembling an accurate census of an entire field from online information alone ,
this system will facilitate new research on the composition of academic fields | This example is circumstance. | pragmeval/gum |
0entailment
| that even the soviets now wonder about an agency that seemed so congenial to them
"but soviet foreign minister eduard shevardnadze last year admitted, ""the exaggerated ideological approach undermined tolerance intrinsic to unesco" | This example is Instantiation. | pragmeval/pdtb |
0entailment
| okay cool
don't think it's quite been finalised yet | This example is Correction. | pragmeval/stac |
2contradiction
| i believe there is special dispensation for those who've never had a chance to hear the good news. the last pope mentioned something dealing with this a few years ago iirc. this is also why the great commision for christians is evangelism.
but you know what really doesn't make sense? why are they evangelising to people (who they know most of them will reject them) if those people get a special dispensation? they'd be condemning people to hell by evangelizing, would they not? why not leave the people be and let them get the special dispensation? emoticonxconfused | This example is sarc. | pragmeval/sarcasm |
0entailment
| perhaps , yes | This example is Negative. | silicone/sem |
2contradiction
| hold the line just a moment please now when you say you know it's the right number did you get it from a or let me try the call for you sir who is it you're trying to call this is a business number you're calling sir the reason that you might not be getting an answer is that you might be it receives incoming calls barred i think incoming calls barred so you can't ring that number it's not a residential number either okay bye | This example is thank-identifySelf. | silicone/oasis |
0entailment
| Do I ever . | This example is positive. | silicone/meld_s |
2contradiction
| Do I ever . | This example is sadness. | silicone/meld_e |
0entailment
| well i've got a great viewpoint here just below the east lake | This example is explain. | silicone/maptask |
2contradiction
| okay , if you'll please fill out these forms ... ( she hands the forms to the customer . ) there's a minimum initial deposit of $ 100 for the checking account , and a minimum deposit of $ 500 for the savings account . | This example is anger. | silicone/dyda_e |
0entailment
| okay , if you'll please fill out these forms ... ( she hands the forms to the customer . ) there's a minimum initial deposit of $ 100 for the checking account , and a minimum deposit of $ 500 for the savings account . | This example is directive. | silicone/dyda_da |
0entailment
| Are you kidding? We'd miss it. We just got here. What's the point of coming down here if we just turn around and go home? | This example is fru. | silicone/iemocap |
2contradiction
| 329 U.S. 362
67 S.Ct. 340
91 L.Ed. 348
PEOPLE OF STATE OF ILLINOIS ex rel. GORDON, Director of Labor,v.CAMPBELL, Collector of Internal Revenue.
No. 35.
Reargued Nov. 19, 1946.
Decided Dec. 23, 1946.
[Syllabus from pages 362-364 intentionally omitted]
Mr.Albert E. Hallett, of Chicago, Ill., for petitioner.
Mr. J. Louis Monarch, of Washington, D.C., for respondent.
Mr. Justice RUTLEDGE delivered the opinion of the Court.
1
This case was companion to People of State of Illinois ex rel. Gordon v. United States, 328 U.S. 8, 66 S.Ct. 841, decided last term, but brings for settlement other problems raised by a conflict of claims between the United States and the State of Illinois. The conflict concerns whether one or the other claimant is entitled to priority of payment from assets of a common debtor. The Illinois Supreme Court dealt with both cases in a single opinion. 391 Ill. 29, 62 N.E.2d 537. Certiorari was granted in each. 327 U.S. 771, 66 S.Ct. 683; 327 U.S. 772, 66 S.Ct. 683. On the same day that People of State of Illinois ex rel. Gordon v. United States, supra, was decided this case was restored to the docket and assigned for reargument before a full bench, People of State of Illinois ex rel. Gordon v. Campbell, 66 S.Ct. 957, because of the presence of the questions not determined by that decision.
2
The controversy arose on June 29, 1942, when the Director of Labor of Illinois brought suit in the Circuit Court of Cook County, Illinois, to enforce against the Chicago Waste and Textile Company a statutory lien for unemployment compensation contributions due the state. Associated Agencies, Inc.,1 was a creditor of the Chicago Waste and Textile Company. In his complaint the Director alleged that Associated Agencies had obtained a judgment against its debtor in the Municipal Court of Chicago and that execution had issued on this judgment June 3, 1942, but that the interest of Associated Agencies was subordinate to that of the lien sought to be foreclosed. This, 'for the reason that the execution upon said judgment was issued long after notice of the lien of the Director of Labor was recorded with the Recorder of Deeds.'2 The Director alleged further upon information and belief that the Chicago Waste and Textile Company was insolvent and that 'the personal property subject to the lien herein being foreclosed, is scant secu ity for the debt due the Director of Labor * * * and that unless a receiver be appointed for all of said property, pending a full and complete hearing upon the issues herein, the plaintiff will suffer financial loss and said property will be wasted.'
3
Granting the immediate relief requested, the Circuit Court enjoined all creditors of the Chicago Waste and Textile Company from interfering with the property of the company, whether by judicial action3 or otherwise, and also appointed a receiver 'for the property of the Chicago Waste and Textile Company.'
4
Subsequently respondent, the Collector of Internal Revenue for the First District of Illinois, filed claims on behalf of the United States amounting to $1,954.07 plus interest. Of this amount, $522.91 was for federal insurance contribution taxes and $1,431.16 was for federal unemployment taxes. Of the federal insurance contribution taxes, $229.91 represented employees' taxes, see Helvering v. Davis, 301 U.S. 619, 57 S.Ct. 904, 81 L.Ed. 1307, 109 A.L.R. 1319, collected by the employer under statutory withholding provisions. Internal Revenue Code §§ 1400, 1401, 26 U.S.C.A. Int.Rev.Code, §§ 1400, 1401. The Collector also filed an intervening petition, alleging that the debtor was insolvent and asking that the claims of the United States be allowed as claims entitled to priority of payment immediately after costs of administration and before payment of other creditors. The Director of Labor answered, denying that the claims of the United States were entitled to priority over the claims of Illinois.
5
The receiver realized $677.81 from sale of the debtor's property and this amount was deposited with the clerk of the Circuit Court. A hearing was held, and the court ordered that ninety per cent of the funds on deposit be given to the Director of Labor and the other ten per cent to the United States. The Collector appealed to the Appellate Court for the First District. On motion of the appellee, the cause was transferred to the Supreme Court of Illinois on jurisdictional grounds.
6
The state Supreme Court held that the United States was entitled to priority over the State of Illinois as to its claim for federal insurance contribution taxes.4 Whether it was correct to award this priority is the issue we now have to decide.
7
People of State of Illinois ex rel. Gordon v. United States, 328 U.S. 8, 66 S.Ct. 841, held that in circumstances which called into application Rev.Stat. § 3466, 31 U.S.C. § 191, 31 U.S.C.A. § 191, the claims of the United States for federal insurance contributions taxes under Title 8 of the Social Security Act, 49 Stat. 620, 636, 42 U.S.C.A. § 1001 et seq., and for federal unemployment compensation taxes under Title 9 of the Social Security Act, 49 Stat. at page 639, 42 U.S.C.A. § 1101 et seq., had priority over claims of Illinois for taxes under its Unemployment Compensation Act.5 That decision is controlling, of course, upon the same feature of this case, although the federal insurance contributions taxes claimed by the United States arise under the 1939 am ndments of the Social Security Act, rather than, as in the case last term, under the original act itself. Compare §§ 801, 802, 804, 807(c) of the original Social Security Act, 49 Stat. 620, 42 U.S.C.A. §§ 1001, 1002, 1004, 1007(c), with §§ 1400, 1401, 1410, and 1430 of the Internal Revenue Code, 53 Stat. 175 as amended by 53 Stat. 1381, 26 U.S.C.A. Int.Rev.Code, §§ 1400, 1401, 1410, 1430.
8
* But the state urges that § 3466 does not apply in the facts of this case. This argument, as well as another, that the lien of the state was so specific and perfected as to defeat the priority, if any, of the United States under Rev.Stat. § 3466, must be met before the case can be affirmed on the authority of People of State of Illinois ex rel. Gordon v. United States, supra.
Rev.Stat. § 3466 provides:
9
'Whenever any person indebted to the United States is insolvent, or whenever the estate of any deceased debtor, in the hands of the executors or administrators, is insufficient to pay all the debts due from the deceased, the debts due to the United States shall be first satisfied; and the priority established shall extend as well to cases in which a debtor, not having sufficient property to pay all his debts, makes a voluntary assignment thereof, or in which the estate and effects of an absconding, concealed, or absent debtor are attached by process of law, as to cases in which an act of bankruptcy is committed.'
10
The fifth act of bankruptcy, which is the one on which the Government relies as having brought § 3466 into operation, consists of a person's6 having,
11
'(5) while insolvent or unable to pay his debts as they mature, procured, permitted, or suffered voluntarily or involuntarily the appointment of a receiver or trustee to take charge of his property.' 52 Stat. 844, 11 U.S.C. § 21, sub. a, 11 U.S.C.A. § 21, sub. a.
12
The state contends, first, that the receiver appointed at its instance was not a receiver within the meaning of this provision and, second, that the Chicago Waste and Textile Company was not shown by the record to be insolvent.
13
This Court has noted that the view has been expressed that to satisfy the fifth act of bankruptcy 'the receivership must be general, as contrasted with a receivership incidental to the enforcement of a lien.' Duparquet Huot & Moneuse Co. v. Evans, 297 U.S. 216, 224, 56 S.Ct. 412, 416, 80 L.Ed. 591.7 It has not determined the correctness of that view, Emil v. Hanley, 318 U.S. 515, 521, note 5, 63 S.Ct. 687, 690, 8 L.Ed. 954, nor need we do so now. For, though the receiver was appointed at the instance of a secured creditor, as in United States v. State of Texas, 314 U.S. 480, 483, 484, 62 S.Ct. 350, (351), 352, 86 L.Ed. 356, 'any limitations upon the operation of § 3466 (with) might otherwise have flowed from this circumstance * * * were removed by the subsequent character of the proceeding.' The receiver was placed in control of all the assets of the Chicago Waste and Textile Company, and all of the assets were liquidated. At least one party other than the secured creditor which had instituted the proceeding, namely, the United States, was allowed to intervene and was heard. 'We think that realities require us to treat the proceeding as a general equity receivership within the scope of § 3466.' United States v. State of Texas, supra.
14
Moreover, it is questionable whether the fact of insolvency is properly contestable by the State of Illinois. The receiver was appointed upon the allegations of its complaint, which included insolvency, and the state admitted in its answer to the Government's intervening petition that the debtor was insolvent. Although ordinarily the doctrine of estoppel or that part of it which precludes inconsistent positions in judicial proceedings is not applied to states,8 in the present litigation Illinois is in the position of any lien creditor.
15
It would seem therefore that in these circumstances the state should be held estopped to contest insolvency. But in any event the record demonstrates that the debtor was insolvent at the time of the appointment of the receiver, for when its property was liquidated there was not enough to satisfy the claims of the two contesting creditors at the bar.
16
Thus, the fifth act of bankruptcy was committed and in consequence the United States has the benefit of the priority given it by Rev.Stat. § 3466. We therefore turn to the argument of the state that the specificity of its lien defeated this priority.
II
17
The United States was given the priority now incorporated in Rev.Stat. § 3466, in 1797, 1 Stat. 515.9 See also the discussion in Price v. United States, 269 U.S. 492, 500, 501, 46 S.Ct. 180, 181, 70 L.Ed. 373. Yet the Court has never decided whether the priority is overcome by a fully perfected and specific lien. See Rogee, The Differences in the Priority of the United States in Bankruptcy and in Equity Receiverships (1929) 41 Harv.L.Rev. 251, 267-270. The question, however, has been reserved many times in express terms. See Conard v. Atlantic Insurance Co., 1 Pet. 386, 442, 7 L.Ed. 189; Brent v. Bank of Washington, 10 Pet. 596, 611, 612, 9 L.Ed. 547; Spokane County v. United States, 279 U.S. 80, 95, 49 S.Ct. 321, 325, 73 L.Ed. 621; People of State of New York v. Maclay, 288 U.S. 290, 294, 53 S.Ct. 323, 324, 77 L.Ed. 754; United States v. State of Texas, 314 U.S. 480, 485, 486, 62 S.Ct. 350, 352, 353, 86 L.Ed. 356. United States v. Waddill, Holland & Flinn Co., 323 U.S. 353, 355, 65 S.Ct. 304, 305, 89 L.Ed. 294.10 And again we need not decide it, for we are of the opinion that the Illinois lien was not sufficiently specific or perfected, in the purview of controlling decisions, to defeat the Government's priority.
18
The effect and operation of a lien in relation to the claim of priority by the United States under Rev.Stat. § 3466 is always a federal question. 'The priority given the United States cannot be impaired or superseded by state law.' United States v. State of Oklahoma, 261 U.S. 253, 260, 43 S.Ct. 295, 298, 67 L.Ed. 638. Hence a state court's characterization of a lien as specific and perfected is not conclusive. United States v. Waddill, Holland & Flinn Co., 323 U.S. 353, 357, 65 S.Ct. 304, 306, 89 L.Ed. 294. The state characterization, though entitled to weight, is always subject to reexamination by this Court.
19
On the other hand, if the state court itself characterizes the lien as inchoate, this characterization is practically conclusive. 'Whatever might have been the effect of more completed procedure in the perfecting of the liens under the law of the state, upon the priority of the United States herein, the attitude of the state court relieves us of consideration of it.' Spokane County v. United States, 279 U.S. 80, 95, 49 S.Ct. 321, 325, 73 L.Ed. 621; cf. United States v. Knott, 298 U.S. 544, 56 S.Ct. 902, 80 L.Ed. 1321, 104 A.L.R. 741.
20
In this case the United States argues that the Illinois Supreme Court judged the lien of the state inchoate and that therefore we may affirm its judgment on this basis. Illinois, however, disputes this reading. It states that the Illinois court did not consider the nature of the lien in relation to the facts presented by this case, but merely determined that under the facts of People of State of Illinois ex rel. Gordon v. United States, supra, the lien had not become choate. We can hardly accept this view in the face of the judgment rendered and the opinion's statement of the facts of this case at the outset, together with the later explicit reference to it in holding the lien not of a sort to defeat the federal priority. But we do not stop to analyze the opinion of the Supreme Court of Illinois in detail. For it is clear, quite apart from the opinion, that the lien was not so specific and perfected as to defeat the priority of the United States, if that is at all possible.
21
The statute under which the Illinois lien arises is set out in the margin.11 The state asserts that the lien became specific and perfected when notice of lien had been filed and recorded12 and when the receiver had been appointed. In its view, upon appointment of the receiver 'all substantial aids to the enforcement of the state's line had been utilized.'
22
With this conclusion we do not agree. It is true that the filing of notice of lien determined the amount of the lien, though the state may have computed wrongly the amount of taxes owed it.13 See United States v. Waddill, Holland & Flinn Co., 323 U.S. at pages 357, 358, 65 S.Ct. at pages 306, 307, 89 L.Ed. 294. But it is not enough that the amount of the lien be known. The lien must attach to specific property of the debtor. This the Illinois lien had not done at the time the receiver was appointed.14 Indeed, as was stated at the argument, not only was the property not in the hands of the bailiff, but so far as appears the amount or type of property belonging to the debtor was not known to the state.
23
Under the Illinois law, where it is sought to foreclose a lien for unemployment compensation taxes it is not necessary for the Director in his complaint to describe the property to which said lien has attached.15 On the contrary by express provision,
24
'* * * it shall be the duty of the employer against whom such petition has been filed to file in said proceedings, a full and complete schedule, under oath, of all personal property and rights thereto which he owned at the time the contributions, upon which the lien sought to be foreclosed is based, become due, or which he subsequently acquired, indicating upon such schedule the property so owned by such employer which was, or is used by such employer in connection with his trade, occupation, profession or business, and if such employer shall so fail to do after having been so ordered by the court, he may be punished as in other cases of contempt of court.' Jones Ill.Stat.Ann. (1944) § 45.154(e), Smith-Hurd Stats. c. 48, § 243(e). (Emphasis added.)
25
Not until the debtor has filed the required schedules16 would the state know the amount of property in the debtor's possession or, more important, the property to which the lien attached. For the lien attaches only to personal property used by the employer 'in connection with his trade, occupation, profession or business. * * *'
26
The appointment of a receiver, then, was only an initial step in the perfecti n of the lien. It, together with the injunction, protected whatever rights in the property the state might have. But it was not a final assertion or attachment of rights to specific property, as is, for example, the enforcement of a judgment by execution and levy. Conard v. Atlantic Ins. Co., 1 Pet. 386, 443, 444, 7 L.Ed. 189.
27
The state has not relied merely upon the recording of the notices of lien but has rested on this together with the receiver's appointment as accomplishing the required specificity and perfection. But now it is said the filing of the notices alone achieved this result. Neither view is correct. Both have been repudiated by repeated decisions of this Court, th latest being United States v. Waddill, Holland & Flinn Co., supra.
28
It has never been sufficient to show merely a general lien, effective to protect the lienor against others than the Government, but contingently on taking subsequent steps either for giving public notice of the lien or for enforcing it.17 Conard v. Atlantic Ins. Co., 1 Pet. 386, 444, 7 L.Ed. 189; United States v. Waddill, Holland & Flinn Co., supra. The federal priority is not destroyed by state recording acts any more than by state statutes creating or otherwise affecting liens, if the lien as recorded or otherwise executed does not have the required degree of specificity and perfection. Under the decisions the test is not, and cannot be, simply whether by his taking further steps, the lienor's rights will be enforced against others than the Government.
29
The long established rule requires that the lien must be definite, and not merely ascertainable in the future by taking further steps, in at least three respects as of the crucial time. These are: (1) the identity of the lienor, United States v. Knott, 298 U.S. 544, 549, 551, 56 S.Ct. 902, 905, 80 L.Ed. 1321, 104 A.L.R. 741; (2) the amount of the lien, United States v. Waddill, Holland & Flinn Co., 323 U.S. 353, at page 357, 358, 65 S.Ct. 304, at page 307, 89 L.Ed. 294; and (3) the property to which it attaches, United States v. Waddill, Holland & Flinn Co., supra; United States v. State of Texas, supra; People of State of New York v. Maclay, supra. It is not enough that the lienor has power to bring these elements, or any of them, down from broad generality to the earth of specific identity.
30
In this case the identity of the lienor was made certain, before the Government's priority attached, both by the statute and by the notices of lien. The latter also fixed the amounts of the liens, though miscalculated. But neither the notices of lien nor the appointment of the receiver made definite and certain the property, as we have shown.
31
Here, as in United States v. State of Texas, 314 U.S. at page 487, 62 S.Ct. at page 353, 86 L.Ed. 356, 'property 'devoted to or used in his business * * *' is neither specific nor constant.' As in United States v. Waddill, Holland & Finn Co., 323 U.S. at page 359, 65 S.Ct. at page 307, 89 L.Ed. 294, the goods subject to the lien had not 'severed themselves from the general and free assets of the tenant (owner) from which the claims of the United States were entitled to priority of payment.' Here, as in that and other cases, there was 'Merely as a caveat of a more perfect lien to come,' People of State of New York v. Maclay, 288 U.S. at page 294, 53 S.Ct. at page 324, 77 L.Ed. 754, whether tested by state law, 323 U.S. at page 357, 65 S.Ct. at page 306, 89 L.Ed. 294, or by perfection 'as a matter of actual fact, regardless of how complete it (the lien) may have been as a matter of state law.' Id., 323 U.S. 358, 65 S.Ct. 307, 89 L.Ed. 294. The state has acquired neither title nor possession, Thelusson v. Smith, 2 Wheat. 396, 4 L.Ed. 271; People of State of New York v. Maclay, 288 U.S. at page 290, 53 S.Ct. 323, 77 L.Ed. 754, since the receiver's possession was that of the court, not of the state; and did not sever the property from the debtor's general assets as of the crucial date.
32
To permit the recording of the notices or the receiver's appointment, or both, in circumstances like these, to overcome the Government's priority would be in substance to overrule the numerous decisions cited in which liens no less 'specific and perfected' have been held impotent for that purpose. It would open the door, too, we think, to substantial nullification of the Government's priority. For then this could be accomplished simply by recorded notices of lien, disclosing claims to property not segregated from the debtor's general estate; designated only by general words of classification, including after acquired property as here; and ascertainable definitively only by further procedures. Congress alone should make such a change, if it should be made at all.
The judgment is affirmed.18
33
Affirmed.
34
Mr. Justice REED, dissenting.
35
In my opinion the notices of lien caused to be duly recorded by Illinois on April 3, May 8 and May 20, 1942, with the Recorder of Deeds of Cook County, Illinois perfected and made specific the state's claim under its unemployment compensation statute. These notices named the creditor and gave his precise address. They stated the amount of the claim and asserted a lien for the aggregate sum upon all the personal property owned and used by the lienee in connection with its business. Under any view of chattel lien law, such a legally recorded instrument would create a lien in the lienor on the personal property owned and used by the taxpayer at his place of business superior to the rights of general creditors or subsequent innocent purchasers for value. This is true by statute in Illinois. Jones Ill.Stat.Ann. (1944) § 45.154(b) (1), Smith-Hurd Stats. c. 48, § 243(b)(1), Unemployment Compensation Act of Illinois.
36
The Court deems that the lien attaches to specific and ascertainable property of the taxpayer only when the taxpayer files his schedule of property in proceedings to enforce the lien.1 I deem the recorded notice as the incident that consummates the lien upon the specific and ascertainable property. The enforcement proceedings after that recordation are only an enforcement of a lien already fixed upon the specific property adequately described in the recorded notice.
37
The Court suggests that the ruling in United States v. State of Texas, 314 U.S. 480, 62 S.Ct. 350, 353, 86 L.Ed. 356, that the statutory lien on 'property 'devoted to or used in his business" is not a specific and fixed lien entitled to priority over the United States, is persuasive that similar words in the Illinois statute are not specific and constant. But in the Texas case, no steps had been taken to fix the amount of the lien on the property devoted to the business, at page 487 of 314 U.S., at page 353 of 62 S.Ct., 86 L.Ed. 356. Of course, therefore, the lien could not be fixed and certain. This final step to perfect the lien had been taken in the present case.
38
As the Court concludes no specific lien attaches to ascertainable property. I content myself with adding, as to the respective priorities of the United States and a lienor with a specific lien on ascertainable property, that in my opinion such a lienor has priority for his lien despite Rev.Stat. § 3466. See Thelusson v. Smith, 2 Wheat. 396, 424, 4 L.Ed. 271; Conard v. Atlantic Insurance Co., 1 Pet. 386, 441, 7 L.Ed. 189; United States v. Waddill, Holland & Flinn Co., 323 U.S. 353, 355, 65 S.Ct. 304, 305, 89 L.Ed. 294.
39
Mr. Justice JACKSON joins in this dissent.
1
Associated Agencies was made a defendant in the suit brought by the Director of Labor.
2
As exhibits to the Director's complaint three notices of lien were filed, one for $225.51, one for $303.29, and one for $259.65. Although these aggregate $788.45, the lien sought to be foreclosed was for $767.29. See note 12.
3
The property of the Chicago Waste and Textile Company was to be sold at public auction at the behest of Associated Agencies. The injunction prevented this sale.
4
This did not exhaust the fund, and the court awarded the balance to the Director of Labor, instead of to the United States in part payment of its claim for federal unemployment taxes. 391 Ill. 29, 32, 34, 62 N.E.2d 537. See also United States v. Spencer, D.C., 65 F.Supp. 763. The United States has not petitioned for certiorari, and therefore the correctness of this disposition of the balance of the fund is not now in controversy.
5
Jones Ill.Stat.Ann. (1944) §§ 45.128—45.161, Smith-Hurd Stats. c. 48, § 217 et seq. The argument of the state in that case was that, since Title 9 contained 'provisions intended to induce states to set up sound unemployment compensation in accordance with Congressionally prescribed standards' and 'to this end' permitted the states 'to build up their own funds by collection from employers within the state of 90% of the tax those employers would otherwise have to pay to the federal government,' (328 U.S. 10, 66 S.Ct. 842) it was Congress' intention to give states priority over the United States for their unemployment compensation claims. This argument was applicable, it may be noted, only to federal unemployment compensation taxes and not to federal insurance contributions taxes which are the only ones involved in this case, since as to federal insurance contributions taxes there are no provisions for federal-state cooperation as there are in Title 9. Compare Helvering v. Davis, 301 U.S. 619, 57 S.Ct. 904, 81 L.Ed. 1307, 109 A.L.R. 1319, with Steward Machine Co. v. Davis, 301 U.S. 548, 57 S.Ct. 883, 81 L.Ed. 1279, 109 A.L.R. 1293. See also Rivard v. Bijou Furniture Co., 68 R.I. 358, 361, 27 A.2d 853.
6
The Bankruptcy Act uses the term 'person,' 11 U.S.C. § 21, sub. a, 11 U.S.C.A. § 21, sub. a, but the Act defines 'persons' as including 'corporations, except where otherwise specified, and officers, partnerships, and women * * *.' 52 Stat. 841, 11 U.S.C. § 1(23), 11 U.S.C.A. § 1(23).
7
Since decision of the Evans case, the fifth act of bankruptcy has been amended to include appointment of a receiver when there is insolvency in the equity sense as well as in the bankruptcy sense. See 1 Collier on Bankruptcy (14th ed.) 475. But under the amended statute the same view has been expressed. Elfast v. Lamb, 2 Cir., 111 F.2d 434, 436.
8
See Note (1946) 59 Harv.L.Rev. 1132, 1136.
9
There are minor differences in phraseology between 1 Stat. 515 and Rev.Stat. § 3466, which 'did not work any change in the purpose or meaning * * *.' Price v. United States, 269 U.S. 492, 501, 46 S.Ct. 180, 181, 70 L.Ed. 373.
10
The statement in United States v. Knott, 298 U.S. 544, 551, 56 S.Ct. 902, 905, 80 L.Ed. 1321, 104 A.L.R. 741, that 'such an interest (an in hoate general lien created by the laws of Florida) lacks the characteristics of a specific perfected lien which alone bars the priority of the United States' was not intended to settle the problem and may be taken to have been made with reference to the early mortgage lien cases discussed and distinguished in United States v. State of Texas, 314 U.S. at pages 484, 485, 62 S.Ct. 350, 352, 86 L.Ed. 356, and People of State of New York v. Maclay, 288 U.S. at pages 293, 294, 53 S.Ct. at page 324, 77 L.Ed. 754.
11
'A lien is hereby created in favor of the Director upon all the personal property or rights thereto owned or thereafter acquired by any employer and used by him in connection with his trade, occupation, profession or business, from whom contributions, interest, or penalties are or may hereafter become due. Such lien shall be for a sum equal to the amount at any time due from such employer to the Districtor on account of contributions, interest and penalties thereon. Such lien shall attach to such property at the time such contributions, interest or penalties became, or shall hereafter become, due. In all cases where a report setting forth the amount of such contributions has been filed with the Districtor, no action to enforce such lien shall be brought after three years from the date of the filing of such report and in all other cases no action to enforce such lien shall be brought after three years from the date that the determination and assessment of the Director made pursuant to the provisions of this Act became final.' Jones Ill.Stat.Ann. (1944) § 45.154(a), Smith-Hurd Stats. c. 48, § 243(a). (Emphasis added.) See also note 2.
12
'Such lien shall be invalid only as to any innocent purchaser for value of stock in trade of any employer in the usual course of such employer's business, and shall be invalid as to any innocent purchaser for value of any of the other assets to which such lien has attached, unless notice thereof has been filed by the Director in the office of the Recorder of Deeds of the county within which the property subject to the lien is situated. * * *.' Jones Ill.Stat.Ann. (1944) § 45.154(b)(1), Smith-Hurd Stats. c. 48, § 243(b)(1), See note 2.
13
Cf. note 2.
14
The priority of the United States attaches upon appointment of the receiver. United States v. State of Oklahoma, 261 U.S. 253, 260, 43 S.Ct. 295, 297, 67 L.Ed. 638; Spokane County v. United States, 279 U.S. 93, 49 S.Ct. 321, 324, 73 L.Ed. 621.
15
Jones Ill.Stat.Ann. (1944) § 45.154(e), Smith-Hurd Stats. c. 48, § 243(e), provides for enforcement of the lien by judicial proceedings for foreclosure. The section states: 'In all such cases, it shall not be necessary that said petition describe the property to which said lien has attached'; and continues with the further language quoted in the text.
16
In his complaint the Director of Labor prayed, 'that an order be entered by this Honorable Court commanding that the defendant, Chicago Waste & Textile Co., a corporation, file within a short day to be fixed by the Court, a full and complete schedule under oath, of all personal property and rights thereto, which it owned on the 1st day of May, 1941, or thereafter acquired, and to indicate upon such schedule the property so owned by it which was or is used by it in connection with its trade, occupation, profession or business.'
17
See the authorities cited in the text at the beginning of Part II of this opinion.
18
As we affirm the judgment of the ground that the United States under Rev.Stat. § 3466 has priority over Illinois as to all federal insurance contributions taxes owing it, we do not consider the argument that even if this general priority did not exist, the United States would be entitled to the amount of the fund which represents employees' taxes.
1
Jones Ill.Stat.Ann. (1944) § 45.154(e), Smith-Hurd Stats. c. 48, § 243(e):
'Foreclosure of Lien. In addition and as an alternative to any other remedy provided by this Act, or by the laws of the State of Illinois the Director may enforce the lien herein created by petition in the name of the People of the State of Illinois to the Circuit Court of the county wherein the property subject to the lien is situated, praying that the lien which has attached to said property, be foreclosed and the aforesaid property be sold in the same manner as in cases of foreclosure of mortgages upon personal property in courts of record. In all such cases, it shall not be necessary that said petition describe the property to which said lien has attached and it shall be the duty of the employer against whom such petition has been filed to file in said proceedings, a full and complete schedule, under oath, of all personal property and rights thereto which he owned at the time the contributions, upon which the lien sought to be foreclosed in (is) based, become due, or which he subsequently acquired, indicating upon such schedule the property so owned by such employer which was, or is used by such employer in connection with his trade, occupation, profession or business, and if such employer shall so fail to do after having been so ordered by he court, he may be punished as in other cases of contempt of court.'
| This example is 8. | lex_glue/scotus |
2contradiction
| Any and all notices or other communications or deliveries required or permitted to be provided hereunder shall be in writing and shall be deemed given and effective on the earliest of (a) the date of transmission, if such notice or communication is delivered via facsimile at the facsimile number set forth on the signature pages attached hereto prior to 5:30 p.m. (New York City time) on a Trading Day, (b) the next Trading Day after the date of transmission, if such notice or communication is delivered via facsimile at the facsimile number set forth on the signature pages attached hereto on a day that is not a Trading Day or later than 5:30 p.m. (New York City time) on any Trading Day, (c) the second Trading Day following the date of mailing, if sent by U.S. nationally recognized overnight courier service, or (d) upon actual receipt by the party to whom such notice is required to be given. The address for such notices and communications shall be as set forth on the signature pages attached hereto. Either party may from time to time change its address for notice by giving at least five (5) days’ written notice of such changed address to the other party. | This example is Integration. | lex_glue/ledgar |
2contradiction
| Een klein meisje loopt op een promenade met blauwe koepels op de achtergrond. | This example is bg. | language-identification |
0entailment
| A pleasant surprise! I expected a further downgrade along the line: The Rock (9)-->Con Air (7)-->Armaggeddon (4). Especially for such an overhyped film. Perhaps that's the reason so few approved of this new type of Bruckheimer fare. Clever dialogue instead of snappy one-liners, decent background/motivation instead of shake-n-bake stereotypes and when the chase came you really thirsted for it. Fanboys expecting an Armageddon rollercoaster: stay away. This is one for the more intelligent action fans. It didn't even bother me Jolie appeared so little. | This example is pos. | imdb |
0entailment
| not for everyone , but for those with whom it will connect , it's a nice departure from standard moviegoing fare . | This example is pos. | rotten_tomatoes |
0entailment
| Coke's Heyer to Go, May Join Starwood NEW YORK (Reuters) - Coca-Cola Co.'s president and chief operating officer, Steven Heyer, will leave the company on Sept. 1 after missing out on the top job in May, the Wall Street Journal said on Tuesday, citing an internal memo. | This example is Business. | ag_news |
0entailment
| Horrible customer service. I brought a box full of toddler clothes on a Friday and was quoted 15 minutes wait for them to look through. After 20 minutes my toddler was getting ansy and I was quoted an additional 15 minutes. I said \"ok we'll be back then\" and went to take my daughter to get a snack. I called to check if the things were ready and was told \"because you left the store your items get looked at after anyone IN the store, and the purchaser has left for the weekend.\" UGH!!! Tell me that before I leave??? \n\nSo we go back Monday morning first thing when they open and ask if they are making offers on any of my items. The girl tells me, \"we're offering $9.60 cash.\" I said \"cool which items did you want to buy?\" and was told she didn't know because they were \"ALREADY TAGGED AND OUT IN THE AISLES.\" I just looked at her and asked why they hadn't made an inventory or asked before they did that. She told me \"Well, you're NOT 'ALLOWED' to refuse the offer because you LEFT THE STORE.\" \n\nWOW. Just WOW........ Scandalous and dishonest, rude and bad business. I told her and the manager I would not be back if this is how they treat customers. The clerk said \"Ok!\" \n\nAVOID\n\nAVOID\n\nAVOID!!!!!!!!! | This example is 1 star. | yelp_review_full/yelp_review_full |
0entailment
| Under the agreement , Larox will transfer 10 employees within engineering and documentation related to delivery projects and product maintenance in Finland to Etteplan as of January 1 , 2007 . | This example is neutral. | financial_phrasebank/sentences_allagree |
2contradiction
| in monumental pomp! no grecian drop | This example is negative. | poem_sentiment |
2contradiction
| The Monkey and the Tiger book pairs two unrelated short gong'an detective novels written by Robert van Gulik and set in Imperial China (roughly speaking the Tang Dynasty). Both stories are fictions based on the real character of Judge Dee (Ti Jen-chieh or Di Renjie) a magistrate and statesman of the Tang court who lived roughly 630–700.The book contains eight illustrations and a map all by the author. | This example is Artist. | dbpedia_14/dbpedia_14 |
0entailment
| Although this is a little old fashioned in its style and content (particularly the photos and graphic style), I was sufficiently engaged with the content and anecdotes to read it right through in one evening. I learnt some new facts and had an insight into the style and ideas of someone who approaches fine lectures and presentations with great care. This made it worthwhile. It is a delightful change not to be assaulted by ego or self assurance. There is one irritating characteristic of style - the repeated use of "granted". | This example is positive. | amazon_polarity/amazon_polarity |
2contradiction
| You sound very similar to Satan in the New Testament when he was tempting Jesus to abandon God by offering him wealth and power . | This example is idk/skip. | hate_speech18 |
0entailment
| May i call You later Pls
| This example is ham. | sms_spam |
0entailment
| ' A lot of work to be done ' : Senator discusses tax reform after Trump <hosts/> bipartisan dinner : microwaves :
' A lot of work to be done ' : Senator discusses tax reform after Trump hosts bipartisan <dinner/> : circus : | This example is sentence1. | humicroedit/subtask-2 |
2contradiction
| Is it cold outside? | This example is ShareCurrentLocation. | snips_built_in_intents |
0entailment
| High thenna bitch that's y I'm tweeting | This example is offensive language. | hate_speech_offensive |
2contradiction
| Fantasy Football Help?
I am loaded at the Running Back position. What two Backs would you start.\nKevin Jones- Arizona\nTiki Barber- Jacksonville\nFrank Gore- Seattle\nThomas Jones- New York Jets | This example is Health. | yahoo_answers_topics |
2contradiction
| NEW YORK (KGUN9-TV) - Arizona Congressman Raul Grijalva has been released from police custody following his arrest in New York Tuesday. The Tucson area legislator was part of a group sitting in the street in front of Trump Tower. He was involved in a demonstration protesting President Donald Trump's plans to end DACA; the order from then-President Obama protecting from deportation undocumented people who were brought to the U.S. when they were too young to have decided on their own to come to this country. Grijalva was charged with two counts of disorderly conduct---one for disrupting traffic, one for refusing to disperse. A public information officer for New York Police says the Congressman was fingerprinted and given paperwork instructing him to appear before a judge at a future date. Police arrested ten people in all. Grijalva has been a vocal critic of President Trump and his policies, and a strong advocate for protecting DACA recipients from deportation. | This example is true. | hyperpartisan_news |
0entailment
| Electrolaryngeal speech is one of the typical types of << alaryngeal speech >> produced by an alternative [[ speaking method ]] for laryngectomees . | This example is USED-FOR. | sciie |
0entailment
| The LM uses the monolingual data and is trained as a five-gram9 using the SRILM-Toolkit ( Stolcke , 2002 ) . | This example is Uses. | citation_intent |
0entailment
| 4 lead to a decrease in SC absorption in mice (Deng et al., 2010; Deng et al., 2012). | This example is background. | scicite |
2contradiction
| The claim ... that we plan to set up panels of bureaucrats with the power to kill off senior citizens ... is a lie, plain and simple. | This example is false. | liar |
0entailment
| mint
gallinula | This example is false. | lexical_relation_classification/K&H+N |
0entailment
| lace
mail | This example is RANDOM. | lexical_relation_classification/CogALexV |
2contradiction
| cello
due | This example is mero. | lexical_relation_classification/BLESS |
2contradiction
| chisel
other | This example is HYPER. | lexical_relation_classification/ROOT09 |
0entailment
| world
everything | This example is IsA. | lexical_relation_classification/EVALution |
2contradiction
| NEW YORK, Nov. 29ÛÓReflecting uncertainty about the direction of interest rates and concern about a deteriorating real estate market, the Dow industrials slipped below 2700 today on a 13-point loss.</br></br>A quarter-point loss on the still jittery bond market only exacerbated a growing sense of nervousness about slowly deteriorating real estate values across the nation, and their possible implications for hard-pressed thrifts and regional banks, market sources agreed.</br></br>Analysts tended to zero in on the woes of Great Western Financial Con)., which announced after TuesdayÛªs market close as much as a $200 million charge in the fourth quarter tied to its commercial real estate exposure.</br></br>Great Western stock initially fell 1% to 1754 on early reactions by investors, then remained lower on volume that swelled to more than 2 million shares. It closed at 18%, down 1%. For months the firm has been considered one of the more resilient savings and loans, both fundamentally and on the stock charts. In fact, its shares had traded above $24 as recently as September.</br></br>deteriorating national real estate market also suffered from spillover selling. Federal National Mortgage Association tumbled 2 points to 39%, Homefed Corp. gave up 2 to 30%, and S&Ls such as Calfed and Golden West, as well as regional banks like Bank of . New England, | This example is yes. | crowdflower/economic-news |
0entailment
| It's a chilly one in North Carolina. Here's just a glimpse of what parts of the 5th District looked like this morning. | This example is national. | crowdflower/political-media-audience |
0entailment
| It's a chilly one in North Carolina. Here's just a glimpse of what parts of the 5th District looked like this morning. | This example is other. | crowdflower/political-media-message |
0entailment
| @bbyowls i know but its better than nothing | This example is neutral. | crowdflower/text_emotion |
2contradiction
| @AmericanAir we have been sitting on the plane for over an hour. unacceptable. you have a complete disregard for customer service. | This example is neutral. | crowdflower/airline-sentiment |
0entailment
| RT @milesgrant: Virginia Republican Party mocks those who trust science of global warming - like Bob McDonnell: http://ow.ly/14jM0 | This example is Yes. | crowdflower/tweet_global_warming |
0entailment
| RT @mention Internet. Weather Forecasting. GPS. Commercial Aviation. Freight. Nuclear Energy. What do these things have in common? | This example is Neutral / author is just sharing information. | crowdflower/sentiment_nuclear_power |
0entailment
| @Dannon Company is committed to helping #Americans make better food choices and to eat #yogurt every day @OneYogurt #US | This example is Information. | crowdflower/corporate-messaging |
2contradiction
| It's a chilly one in North Carolina. Here's just a glimpse of what parts of the 5th District looked like this morning. | This example is partisan. | crowdflower/political-media-bias |
0entailment
| I loved every bone in her beautiful body. | This example is acceptable. | ethics/commonsense |
0entailment
| Could you take me shopping for a Homecoming dress next weekend? | This example is unacceptable. | ethics/deontology |
0entailment
| I deserve a bonus from this Mechanical Turk requestor, because I gave him fake data. | This example is acceptable. | ethics/justice |
0entailment
| Joe wanted to climb the corporate ladder but didn't network with the top bosses.
bigoted | This example is acceptable. | ethics/virtue |
2contradiction
| mail are female lolol i'm not a female facewithsteamfromnose what is your work | This example is sad. | emo/emo2019 |
0entailment
| page 149 of 289 in #thedescendant rewrite. very because i'm almost to the half-way point. #newauthor #amwriting #amediting | This example is no-hate-speech. | tweets_hate_speech_detection |
2contradiction
| Gus Gould said it the best: "I get a fair bit of criticism from what I view to be either immature misinformed people who get intimidated by their own insecurities or get intimidated by what they don't understand. I coach for the players, I coach for the game. What I've done over the last three years I don't want any raps for but I don't deserve the shit you've fucking given me. Not one word of it...You tell me what happened tonight. The shit you dished up to me over that, I'll remember it. A few people haven't shown their faces this week but I'll remember it. You go hard, go as hard as you like. You haven't broken me in nine years and you won't break me now." He's not the only one that is sick of the bullshit and prentiousness that occurs in society nowadays. Every one seems to be so goddam self-conscious they wont even tell the truth in case it wrecks their own high view of themselves. E.g. You should be more subtle about what you say... Im not going to say something nice and disembled just to please some person. If its shit, its shit. If its good, its good. Simple, clear-cut statements. None of this "well, it is intriguing and shows you have tried your best." Face it, this means YOUR TERRIBLE. GO GET A NEW HOBBY. The world is a worse place if there are not enough people who will just tell the truth. GOULDY, you wont ever be forgotten. | This example is female. | blog_authorship_corpus/gender |
2contradiction
| Gus Gould said it the best: "I get a fair bit of criticism from what I view to be either immature misinformed people who get intimidated by their own insecurities or get intimidated by what they don't understand. I coach for the players, I coach for the game. What I've done over the last three years I don't want any raps for but I don't deserve the shit you've fucking given me. Not one word of it...You tell me what happened tonight. The shit you dished up to me over that, I'll remember it. A few people haven't shown their faces this week but I'll remember it. You go hard, go as hard as you like. You haven't broken me in nine years and you won't break me now." He's not the only one that is sick of the bullshit and prentiousness that occurs in society nowadays. Every one seems to be so goddam self-conscious they wont even tell the truth in case it wrecks their own high view of themselves. E.g. You should be more subtle about what you say... Im not going to say something nice and disembled just to please some person. If its shit, its shit. If its good, its good. Simple, clear-cut statements. None of this "well, it is intriguing and shows you have tried your best." Face it, this means YOUR TERRIBLE. GO GET A NEW HOBBY. The world is a worse place if there are not enough people who will just tell the truth. GOULDY, you wont ever be forgotten. | This example is Gemini. | blog_authorship_corpus/horoscope |
0entailment
| Gus Gould said it the best: "I get a fair bit of criticism from what I view to be either immature misinformed people who get intimidated by their own insecurities or get intimidated by what they don't understand. I coach for the players, I coach for the game. What I've done over the last three years I don't want any raps for but I don't deserve the shit you've fucking given me. Not one word of it...You tell me what happened tonight. The shit you dished up to me over that, I'll remember it. A few people haven't shown their faces this week but I'll remember it. You go hard, go as hard as you like. You haven't broken me in nine years and you won't break me now." He's not the only one that is sick of the bullshit and prentiousness that occurs in society nowadays. Every one seems to be so goddam self-conscious they wont even tell the truth in case it wrecks their own high view of themselves. E.g. You should be more subtle about what you say... Im not going to say something nice and disembled just to please some person. If its shit, its shit. If its good, its good. Simple, clear-cut statements. None of this "well, it is intriguing and shows you have tried your best." Face it, this means YOUR TERRIBLE. GO GET A NEW HOBBY. The world is a worse place if there are not enough people who will just tell the truth. GOULDY, you wont ever be forgotten. | This example is indUnk. | blog_authorship_corpus/job |
0entailment
| How old is too old to dock a dogs tail? | This example is extent. | open_question_type |
0entailment
| Rhode Island will become just the second state to mandate the vaccine … and the only state to do so by regulatory fiat, without public debate, and without consideration from the elected representatives of the people. | This example is mixture. | health_fact |
0entailment
| Islam later emerged as the majority religion during the centuries of Ottoman rule, though a significant Christian minority remained. What day did Islam emerge as the majority religion? first sunday | This example is no. | mc_taco |
0entailment
| The patient recovered without permanent sequelae. | This example is Not-Related. | ade_corpus_v2/Ade_corpus_v2_classification |
2contradiction
| X wants to know about Y's music preferences. Is reggae your thing?
It's good music for chilling in the summer. | This example is Other. | circa |
0entailment
| To begin with, It's in the best interest of the people that we should'nt have a Electoral College | This example is Adequate. | EffectiveFeedbackStudentWriting |
2contradiction
| additional use : The Dominican flute tradition declined as a result, despite their additional use in serenades, until being revived after the National Independence Competitions. :
musical implementation : The Dominican flute tradition declined as a result, despite their musical implementation in serenades, until being revived after the National Independence Competitions. : | This example is negative. | phrase_similarity |
0entailment
| Scientists have identified a protein that acts as a “master switch” in certain white blood cells, determining whether they promote or inhibit inflammation. The study, published in the journal Nature Immunology, could help researchers look for new treatments for diseases such as rheumatoid arthritis that involve excessive inflammation.
High expression of IRF5 was characteristic of M1 macrophages, in which it directly activated transcription of the genes encoding interleukin 12 subunit p40 (IL-12p40), IL-12p35 and IL-23p19 and repressed the gene encoding IL-10. | This example is same. | scientific-exaggeration-detection |
0entailment
| The mammoth moved slowly through the watering hole, but ran on the hard dirt because the hard dirt had (A) less resistance (B) more resistance | This example is A. | quarel |
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