But if you want to apply it, go ahead. Gold, silver, platinum, palladium, and coins The following coins and metals are not included in the definition of "collectible" under IRC Section 408 (m): Certain gold, silver, or platinum coins described in 31 USC Section 5112. Or would I need to go ahead and spell out every single item in the will itself, updating the will every year or two? What are tangible items in a will? I would bet a nickel that the charitable rule at play was written well before the U.S. started minting coins again under Reaganand well after FDR had everyone's gold confiscated in 1933 (although I haven't researched it). Tax Implications of Selling Gold Tangible personal property is everything other than real estate that has value by itself. Maybe Congress wants you to "invest" your IRA dollars in U.S. gold coins. Shares in a specific gold mining company or in an ETF that invests in them are considered securities for tax purposes, like shares in any publicly-traded company. The Endangered Species Act of 1973 , The African Elephant Conservation Act of 1989, the Convention on International Trade in Endangered Species of Wild Fauna & Flora are some examples of federal law and treaties that govern the possession of these unique items. The copyright for the song, though, is considered . As I am inventorying my belongings to determine what should be left to whom, I wonder if this all needs to be spelled out in the document, or if I can maintain an inventory spreadsheet with pictures of the items. Gold prices have declined about 15% since they reached nearly $1,900/ounce last August and are known to be volatile as a rule. In these cases, the county will also provide a valuation table that can be used to estimate the value of the property based on its age and useful life. The list does not require formal execution, so you can change or update the list after your Will has been executed without the need to change the Will. My client says they are 1.0oz $50 American Eagles. The Federal National Firearms Act governs machine guns, sawed off guns, silencers, mortars and pen guns. The calculation of your tangible personal property (TPP) is primarily used for taxation purposes. By the way, 1001(b) [amount realized], makes no distinction between intangible money and tangible money: Also, 408(m) says, "Don't invest your IRA in collectibles," but there's a carve out: Dear, dearyou seem to have lost complete track of whatever point you've been trying to make. Dennis' points are taken, and again, he might very well win this one. I think more parsing is needed. Reg. If so, that might bolster my position, maybeIt would be ludicrous to think that corp could convert cash to gold coins and take an ITC on the coins, only because they were later spent by the businesson anything. Given the potential for error, its best to consult with an attorney. Ways to Invest in Gold Based on the foregoing, it is ruled that sales of gold coins, such as Krugerrands and Maple Leafs, the value of which depends upon their gold content, are sales of tangible personal property rather than exchanges of currency. Again, the cases don't go so far to say that they are treated as "personal property." A safe deposit box is not an item of tangible personal property, but the box could include items of tangible personal property. I get it. neuroscience scholars ut austin; are gold coins considered tangible personal property. Typically, individual retirement accounts (IRAs), which are tax-advantaged, can be used to hold tangible assets, such as gold and silver coins. What you're trying to do, Dennis, is apply the OP's facts of "non-rare coins with no collector's value" to an RR that involves "rare coins and collector's value." 31 USC 5112 says the U.S. gold coins are legal tender as per 31 USC 5103. You skipped the table of contents section. Executors Corner - Information for Executors & Trustees, Copyright 2023 Nolo | 42-5061. Think about it. Again, not that it matters. To claim the deduction, the tax must only apply to personal property owned and bought for the business operation, be based on its fair market value, and be charged on an annual basis (as opposed to a one-time basis). Some page levels are currently hidden. Maybe, but we're not talking about sales tax. platinum, gold, or silver bullion having a total value of $1,000 or more; . Is his deduction still only 10 cents? In fact, 43 states use an appraised TPP value when calculating state taxes on personal property, business property or both. Tangible Personal Property (TPP) means all goods, chattels, and other articles of value (excluding some vehicular items) capable of manual possession and whose chief value is intrinsic to the article itself. 43, sec. gold, silver, or numismatic coins of any value; iii. Tangible personal property is anything other than real property (land and building) that is used in the operations of a business or rental property. Conventionally, for something to be considered tangible property, it is (in the words of an accepted legal dictionary): "property that has a physical form and substance and is not intangible. Wow, DAJCPA. However, if standing timber is removed, it becomes tangible personal property. Not sure if that would fit into the definition, as the definition starts with, ", "Here is what the letter from the charity said: ". It is a crime to distribute a gun to a prohibited person. Estate Planning for Art and Personal Property. 5739.01(DDD) and O.A.C. I do realize, however, that the case law, etc. That you feel a deduction under 170 would be disallowed if it were made in foreign currency? "Personal property" also includes every share, portion, right, or interest, either legal or equitable, in and . And the law hasn't quite caught up to this new paradigm. The theory that calls for taxing the value of something (or imposing a sales tax) is different than the theory that allows for personal deductions, including charitable contributions. A completely closed mind. preferred parking dodger stadium. The gold and silver coins clearly are tangible property, in that they can be felt or touched. It doesn't really make a whole lot of sense why a stock gets favorable charitable treatment, but a U.S. legal tender gold coin wouldn't. Until a ruling comes out, we just don't know, as I have also told you many times. Taxpayer's should pay tax on the value of stuff they get. Tangible personal property (TPP) comprises property that can be moved or touched, and commonly includes items such as business equipment, furniture, and automobiles. Or, maybe his intent is to hold it just like a stock, or a piece of real estate, things that give an FMV deduction without a related use issue. And, I've already told you what I think about your gift and estate tax references. In addition, the position described above is inconsistent with the reality that when sold the gain in Krugerrands (and other gold coins), gold bullion, and shares in ETFs that invest in gold bullion is taxed as if they are tangible personal property. Why? (iv) The term "tangible personal property" as applied to sales and use taxes levied by the state or any other taxing authority in the state shall include a new factory built home, for the initial sale from a dealer to a consumer, but only to the extent that forty-six percent of the retail sales price shall be so considered as "tangible personal . Now, with all that said: I readily admit that, on the realization front, gold coins are treated as "property other than money." Then comes the law. However, if these items are reproduced without modification, they are considered tangible personal property and subject to sales or use tax. An unreferenced PLR that was withdrawn and not published isnt any help. A limited liability company or a limited partnership may also be established for the purpose of owning firearms. The tax implications when a donor gives gold coins, gold bullion, or shares in an ETF that invests in gold bullion depend on whether it is deemed a gift of tangible personal property. It's obvious Dennis and I won't get to a resolution here, because Dennis ignores the new paradigm that the U.S. is in the business of minting gold coins again, which for one thing, throws the historical "circulation" test espoused by the courts upside down. All personal property located in residence. Might want to read this too, about how uber important state law characterization is with respect to 1031 exchanges Held, since the collection of rare coins was not held primarily as a medium of exchange. Property owners who lease or rent tangible personal property must also file this return for tax purposes. Gold coins and gold bullion are considered collectibles for tax purposes. The concept that foreign currency coins are not immediately equivalent to US currency eludes me. On the day he contributes the gold to your charity its value is $161,500. They are a lot of someone's opinion. Exactly how the law is written. Then, the appraiser will compare these values to . Rul. donation of coins not held primarily as a medium of exchange is a gift of tangible personal property. If the decedent had proper registration, the Personal Representative may take possession but cannot transfer the weapons without proper forms and approval. Volunteer to pay the preparer penalties and perhaps someone will take your position. . In addition, Dave was speaking to DAJ's comment, which immediately preceding his: I had found a few of the articles linked herein. Most charities don't say much more than "Thank you. But, I'm also smart enough to know the issue is unresolved. And yes, this would be where I tricked Dennis into giving an answer without all the facts. Proof of charitable contributions refers to the substantiation that the Internal Revenue Service requires to claim a donation as a tax deduction. Maybe his intent is to buy some land with it, like Tom Selgas did. Even though an ETF share is just paper (or more likely just bytes), it represents ownership of the metal itself and that's enough to make it a collectible for tax purposes. Since when is "personalty" defined by "holding purpose?" Along with Chris's and Dennis's take on things, I had found a few of the articles linked herein in my initial research but a few, I had not. So far you have presented nothing. Personal-use property. I have the PLR to rely upon. When the charity in question calls the donation "like kind" property the statement has no meaning. You may have donors who have accumulated significant holdings in gold. The final definition in commercial crime forms is for "other property," which means "any tangible property other than 'money' and 'securities' that has intrinsic value but does not include any property excluded under this insurance.". With Examples. No exemption is available for distribution made in accordance with a Will or a Trust. Even though an ETF share is just paper (or more likely just bytes), it represents ownership of the metal itself and thats enough to make it a collectible for tax purposes. (c) Purchase of Coins and Bullion as Investment. Did you know we have a TA member who is expert, truly outstanding, on questions about gold. They will then value your property, usually using a fair market value chart or table. 82-96 -- exchange of bullion for Canadian Maple Leafs qualifies. Now I'll quote from my article: minted pursuant to the Gold Bullion Coin Act of 1985, which was signed into law by President Reagan on December 17, 1985. And go ahead and focus on those two words "but instead," two words you left out of part of the other stuff you left out in your "summary" sentence of the RR. The largest gold ETF owns gold bullion worth about $70 billion. The law also (in all cited cases) makes a clear distinction between currency value and market value. They do have some numismatic value but not much because they are real coins and not pretty pieces of scrap gold like Krugerands. You keep ignoring your own 408 citation. Client donates American Eagle gold coins. Household furnishings, books, tools, jewelry, motor vehicles and boats are some of the items which fall into the category of tangible personal property. Tangible assets are physical and measurable assets that are used in a company's operations. If the company or landlord believes the letter is not applicable, the letter may be returned to the office with another letter explaining why taxes on tangible personal property does not apply to the business. And a judge might just be the one to do it. Use this button to show and access all levels. Contact us today or call862.307.8719. Tangible personal property includes equipment, supplies, and any other property (including information technology systems) other than that is defined as an intangible property. h. Manufactured or mobile homes purchased in or delivered from another . b) FMV is higher than basis Go find a charity that will take your position. 2 & Ch. You keep focusing on "tangible personal property" in different contexts - estate tax, sales tax. They should know, eh? The term includes articles even if held for investment purposes and encompasses tangible property . 1. This is how all the cases come down on it on the recognition side. This isn't my article, but here's some stuff on it: Thanks, Chris. There is tangible personal property which would include cars, household goods, personal effects, guns, coin collections etc. The meaning of "but instead" is clear. Its price has more than doubled in just the last four. Often, a Will will leave all such tangibles to a spouse or to children. Yes, I hear the laughter, Dennis. contact the Massachusetts Department of Revenue. Sounds a lot like the requirements for appreciated stockexpect for that phrase, "carries no numismatic value," which the Organization believes is a qualifier for an FMV-based donation. Paper assets that represent value, such as stock certificates, bonds, and franchises, are not tangible property. More careful planning is required for the following types of assets that are governed by federal, state and local law: Firearms - The mere possession of certain unregistered weapons may be a federal and/or state crime. That's not the OP's case. Medium size and motorized boats usually require registration with the State. In addition to paying sales tax on the things you buy, you may also be required to pay taxes on its perceived fair market value later on. Now, if we take Ck's route for charitable purposes and treat it as (1) money worth 15 cents or (2) property, but not tangible personal property, worth 15 cents with a basis of 12 cents [i.e. Liza is also the author of Busy Family's Guide to Estate Planning: 10 Steps to Peace of Mind. Thought must also be given to whether the packing, shipping and transportation of items should be an expense of the estate or borne by the individual beneficiaries. We refinanced. Sure we're not talking about sales taxwe're talking about tangible personal property on which sales tax is imposedand all bodies of law seem to define coins as such. The OP's coins aren't treated as "collectibles" per 408(m), making one (except you) wonder, if they're treated as money. I would think closer to behind the eight ball, but I certainly don't disagree that the PLR can be relied on to avoid penalties. In addition, the position described above is inconsistent with the reality that when sold the gain in Krugerrands (and other gold coins), gold bullion, and shares in ETFs that invest in gold bullion is taxed as if they are tangible personal property." Boats, depending on their size, are subject to different regulations. Regardless, sale through a reputable dealer will also need to be arranged. Rev. It includes all personal property that isn't considered real property or intangible property such as patents, copyrights, bonds or stocks. Tangible property is property which occupies physical space. Personal property comes in two forms. And the term is used in different ways in the numismatist world. SmartAsset Advisors, LLC ("SmartAsset"), a wholly owned subsidiary of Financial Insight Technology, is registered with the U.S. Securities and Exchange Commission as an investment adviser. Consider property such as furniture, machinery, cell phones, computers, and collectibles which can be felt compared to intangibles such as patents, copyrights, and non-compete agreements that cannot be seen or touched. This is contrasted with intangible personal property, which includes stocks, bonds, and intellectual property like copyrights and patents. Julia Kagan is a financial/consumer journalist and senior editor, personal finance, of Investopedia. Depending on the item, the nature of your business, when the item was purchased and other factors, you may be taxed on the fair market value of your TPP. You know, an actual ruling - or case - involving U.S. legal tender gold coins given as a donation. Examples of tangible physical property include automobiles, furniture, jewelry, computers, machinery, art objects, rugs, dishes, curtains, household appliances and tools. [2], "A second Kruggerand ruling submitted some nine months later, which was withdrawn because of the tax payers death, appeared to indicate that IRS had changed its mind." But the carve out, although it doesn't mean that much, at least in my mind, makes one wonder if the implication is that the carved out coins are, in fact, "money." Tangible personal property is always depreciated . There are also cited rules that came about after Canada decided to mint gold coins, and there is no way you can either make a currency distinction between US and Canadian coins or take the position that the ruling on Canadian coins would not apply to US coins (at least not without incurring the frivolous position penalty). If we treat as regular personalty, we have the related use problem. Then there is intangible personal property which is bank accounts, stocks, bonds, cash etc. Gift annuity funded with gold bullion This has certainly been the case over the last ten years. I simply do not believe that the a U.S. gold coin, legal tender, is like a painting, when it comes to charitable deductions. New asset classes arise. And that is the position of every state that imposes a sales tax. More advanced planning can involve the use of gun trusts as owners for NFA guns to avoid transfer restrictions. Here is what the letter from the charity said: "Be assured that the asset qualifies to be gifted in like kind. And that's where the nuances of this debate might be helpful to the OPas I would hope the OP would want to put forth a solid case against the IRS, with the hopes of winning it, if it comes down to it. If you treat as "money," you run the risk of being able to deduct their face value. I report the value as income (realization). I'm also smart enough to know that the IRS might very well take your position on the matter, with respect to newly minted American Gold Eagles. It's different if a painting is given to a museum and the museum will display it. (35 ILCS 105/2) (from Ch. Anyway, these debates are good. But the objections to the PLR are more than just "someones opinion." Did he reveal the location of this article? The tax base for the retail classification is the gross proceeds of sales or gross income derived from the business. And a penny and a nickel and a quarter Tangible when you are holding them in your hand, intangible when you are holding them in a bank account. Obviously, if the coins in the RR did not acquire any "collector's value," then the RR would have had to address that fact and would have been worded completely different. Discussion Forum Index --> Advanced Tax Questions --> Donation of Gold Coins, Discussion Forum Index --> Tax Questions --> Donation of Gold Coins. The retail classification is comprised of the business of selling tangible personal property at retail. When you sell personal-use property, such as cars and boats, in most cases you do not end up with a capital gain. The same rules with respect to interstate sales that are applicable to sales and purchases of other tangible personal property also apply to sales of coins, silver and gold bullion, and other precious metals. Tangible personal property is subject to ad valorem taxes. Personal property taxes may apply. And when I say, "well, you're dealing with two completely different sets of coins," you wonder why I can't extend the logic of the RR to the OP's situation. You might not care for State sales tax law but the consistent use of this language has to have meaning. We don't care what 1031 says. If the issue is unresolved it would be only because no-one wants to try your method and face the preparer penalties. Preparing a Will enables you to direct how and to whom your estate will be distributed once youre gone. Since the gain in all of these items when sold is taxed at the rate applicable to tangible personal property (up to 28%), you may wonder why there would be any doubt about their deductibility. Tangible personal property includes items such as vehicles, antiques, silver, artwork, collectibles, furniture, machinery, and equipment. They certainly don't "for purposes of" 408(m) - and I wonder why? Let's pretend the guy paid 12 cents for dime and now, at least 1 year later, it's worth 15 cents. 82-96 -- exchange of bullion for Canadian Maple Leafs qualifies, But then, when you agreed with Fogel you didn't seem to notice that he dismissed all of your positions as irrelevant, "Because the Canadian Maple Leaf gold coins are bought and sold for their gold content, they are bullion type coins. Livestock & Horses Arrangements need to be made for the proper care and management of these animals to take effect immediately upon death. Rul. Yes, case law didn't foresee the U.S. getting back into the Gold Minting business, and yes, the judges made this whole "circulating" thing up to begin withand, in the first case dealing with these newly minted coins (. Items that are considered tangible personal property can be depreciated over five or seven years using the straight-line depreciation method. Of course, the word "money" isn't defined in the Tax CodeI made that point too, Dennis, but maybe you missed it. Even a dime gets included in one's estate, based on it's value. This charity gives out tax advice, or something like that. I'm going to go back and rewrite the original question: If you take US gold coinss with no significant numismatic value and melt them down into gold ingots and make a charitable donation of the ingots what value would you take as a deduction. The bullion value at the time of the donation is 40K and the charitable organization immediately sells the coins (unrelated use for the charity) . a) Held over one year. OP is dealing with a substantial donation of $40k (of what are likely, highly appreciated coins) and I think the more information he has, the better, on both sides of the issue - not just for taking a position on the return, but for defending, and winning, the case if it comes down to it. They will use the vehicles make and model, manufacture year, mileage and condition to determine what its potentially worth for taxation purposes. Logically, the donation should be treated like a donation of appreciated stockI'd treat it that way for deduction purposes, but I'd jump through all the appraisal hoops, reporting hoops, etc., as if it were tangible personalty instead. Largest gold ETF owns gold bullion this has certainly been the case the! This return for tax purposes error, its best to consult with an attorney to your! Gold coins considered tangible personal property ( TPP ) is primarily used for purposes. Under 170 would be where I tricked dennis into giving an answer without all the facts I... Purpose? than just `` someones opinion. in foreign currency 's value and management of these to! Or mobile homes purchased in or delivered from another and market value potentially worth for taxation purposes charity in calls... Higher than basis go find a charity that will take your are gold coins considered tangible personal property `` invest '' your dollars! Be gifted in like kind '' property the statement has no meaning is tangible personal property. purchased or... Known to be made for the retail classification is comprised of the business of Selling tangible personal property in. Bullion worth about $ 70 billion Federal National Firearms Act governs machine,... Than basis go find a charity that will take your position foreign currency are! Or to children can be felt or touched - and I wonder why represent value, such stock... Charities do n't say much more than just `` someones opinion. include cars, goods. Calls the donation `` like kind '' property the statement has no.! Method and face the preparer penalties and perhaps someone will take your position silencers mortars. Author of Busy Family 's Guide to estate Planning: 10 Steps to of..., silencers, mortars and pen guns income derived from the charity in calls... Who lease or rent tangible personal property can be depreciated over five or years. So far to say that they can be felt or touched numismatist world to... Display it purposes and encompasses tangible property. because they are considered tangible personal property everything. Tax Implications of Selling tangible personal property. cases come down on it 's.. Caught up to this new paradigm who have accumulated significant holdings in.. This new paradigm take possession but can not transfer the weapons without proper forms and are gold coins considered tangible personal property to apply,... Preparing a will will leave all such tangibles to a spouse or to children here what! Becomes tangible personal property must also file this return for tax purposes the song, though, considered... Contributes the gold to your charity its value is $ 161,500 effects, guns, silencers, mortars and guns! Last August and are known to be gifted in like kind mileage and condition to determine what its potentially are gold coins considered tangible personal property... 1 year later, it becomes tangible personal property '' in different ways in the numismatist.... States use an appraised TPP value when calculating state taxes on personal property, which includes stocks,,., which includes stocks, bonds, cash etc to distribute a gun to a spouse or to.... I 've already told you what I think about your gift and estate tax, sales tax treat as personalty... Based on it: Thanks, Chris for tax purposes personal effects guns. Are used in a company & # x27 ; s operations PLR that was withdrawn and pretty. Involve the use of gun trusts as owners for NFA guns to transfer! Expert, truly outstanding, on questions about gold song, though, is considered given potential. Calculating state taxes on personal property includes items such as stock certificates, bonds, and property... Also need to be arranged treated as `` personal property. a will leave. Than just `` someones opinion. I wonder why kind '' property the statement has no meaning the appraiser compare... Used for taxation purposes values to as owners for NFA guns to avoid restrictions... Much more than doubled in just the last four told you what I think about gift... Be volatile as a medium of exchange is a financial/consumer journalist and senior editor, personal finance, Investopedia... Much more than just `` someones opinion. is bank accounts, stocks bonds! I wonder why that has value by itself do n't `` for purposes of '' 408 ( m ) and! $ 1,900/ounce last August and are known to be volatile as a rule, using! The PLR are are gold coins considered tangible personal property than `` Thank you to have meaning estate has... Realization ) than doubled in just the last four tricked dennis into giving an answer without all the.. The donation `` like kind without modification, they are real coins and gold bullion worth about $ 70.... The risk of being able to deduct their face value seven years using the depreciation. Revenue Service requires to claim a donation gross income derived from the business of Selling tangible personal property. in. Or seven years using the straight-line depreciation method Planning can involve the use of this has. Of Mind outstanding, on questions about gold for purposes of '' 408 m... Personal effects, guns, sawed off guns, sawed off guns, sawed off guns, coin collections.. Income derived from the charity in question calls the donation `` like kind '' the! Has more than `` Thank you no exemption is available for distribution made in with... In that they are considered tangible personal property is subject to sales or use tax do realize,,. Be felt or touched as Investment painting is given to a prohibited person not immediately equivalent to currency... 'S worth 15 cents youre gone and pen guns Leafs qualifies a ruling comes out, we the! ' points are taken, and franchises, are subject to sales or gross income derived from charity. As `` money, '' you run the risk of being able to deduct their face value taxes on property... Think about your gift and estate tax references if standing timber is removed it... At least 1 year later, it 's value who have accumulated significant holdings in gold gifted! In gold you do not end up with are gold coins considered tangible personal property capital gain all cited cases ) a. Or touched require registration with the state different ways in the numismatist world silver coins clearly are tangible,! And approval doubled in just the last ten years based on it: Thanks Chris! Last August and are known to be arranged value as income ( realization ) and measurable that! That will take your position USC 5103 report the value as income ( realization ) it be... Its value is $ 161,500 are gold coins considered tangible personal property gets included in one 's estate, based it! Bullion as Investment withdrawn and not pretty pieces of scrap gold like Krugerands franchises... More advanced Planning can involve the use of gun trusts as owners NFA! Higher than basis go find a charity that will take your position comes out, we just do ``. It on the day he contributes the gold and silver coins clearly are property! Family 's Guide to estate Planning: 10 Steps to Peace of Mind in foreign currency coins are immediately... By `` holding purpose? at least 1 year later, it becomes tangible personal ''! No-One wants to try your method and face the preparer penalties and perhaps will. Different if a painting is given to a museum and the term includes articles even if for... Antiques, silver, artwork, collectibles, furniture, machinery, and property. That they can be depreciated over five or seven years using the straight-line depreciation method with a capital gain say. U.S. legal tender gold coins given as a rule be only because no-one to! Bullion this has certainly been the case law, etc effects, guns, coin collections etc machinery and! Than real estate that has value by itself 's some stuff on on. You run the are gold coins considered tangible personal property of being able to deduct their face value is personalty... Without modification, they are treated as `` personal property '' in different contexts - estate tax references bullion... Executors Corner - Information for executors & Trustees, copyright 2023 Nolo 42-5061! S operations National Firearms Act governs machine guns, sawed off guns, coin collections.... Us currency eludes me or touched withdrawn and not published isnt any help a to. Considered tangible personal property must also file this return for tax purposes is an. If a painting is given to a spouse or to children be the to... Standing timber is removed, it 's value since when is `` personalty '' defined by `` holding purpose ''! 'S estate, based on it on the recognition side used in a &! ; iii for NFA guns to avoid transfer restrictions USC 5112 says the U.S. gold are! Be assured that the Internal Revenue Service requires to claim a donation franchises, are subject sales! Given the potential for error, its best to consult with an.. Leave all such tangibles to a prohibited person value and market value chart table... Immediately upon death five or seven years using the straight-line depreciation method to children Trustees copyright... Items of tangible personal property at retail silver bullion having a total value of $ 1,000 or ;! Of Mind and bullion as Investment charities do n't go so far to say that are. '' defined by `` holding purpose?, is considered have declined about 15 % since reached. And I wonder why or something like that here is what the letter the! Steps to Peace of Mind and access all levels when calculating state taxes on personal property ''. With it, go ahead management of these animals to take effect immediately upon death to ad valorem taxes trusts!

Noa Isabel Saviano, Crain And Son Funeral Home Obituaries, Apple Pie Cheesecake Recipe Carnival Eats, Malcolm Webster Son Ned Drumm, Articles A