Policy Considerations Against Taxing Second Life Wealth - Tim Miano

Despite its prolific number of small dollar transactions, its technological origins in the video game industry, and the initial perception that the utility derived from the activities in Second Life are somehow distinguishable from those in the real world, an analysis indicates that taxation of the wealth generated inside Second Life is proper appropriate under current U.S. tax law. [see other discussion here] Nevertheless, this article concludes with a few comments about some of the policy reasons not to tax Second Life. It also raises the most pressing issues that this paper failed to explore.

First, note that “Second Life’s grant of property rights to participants seems to have encouraged far greater experimentation and innovation than other virtual worlds. For example, one participant created a video game within the Second Life virtual world and then sold it to a real-world media company, a transaction that would be impossible in most virtual worlds.” Additional interesting and bizarre issues concerning Second Life come to light everyday. Just to list a few: John Edwards’s Second Life presidential campaign headquarters was vandalized with feces and a picture of him in blackface; a virtual riot broke out between members of the French extremist party National Front and Second Life Left Unity, a socialist and anti-capitalist user-group; reports have arisen that certain users have designed a way to override the mobility of other users and virtually rape unconsenting avatars; hundreds of companies from H&R Block and Colwell Banker to Coco-Cola and Mercedes Benz have an active business presence in Second Life; Reuters has a dedicated Second Life News center; gambling activities have become so wide-spread that the FBI is investigating the criminal activities by U.S. citizens. In essence, Second Life is allowing the public to explore the practical boundaries of a three-dimensional version on the Internet.

Perhaps most importantly is that this innovation is developing something as yet unseen in the real world or on the Internet: a viable system for micro-transfers of wealth with transaction costs approaching zero. The importance of this point cannot be overstated. The Linden Dollar has remained steadily at about L$270 per $1, so real people are activity engaging in millions of transactions that are valued as low around $0.0037. Thus far, these transactions have been secure and easy to administrate through electronic accounts where people can, in essence, deposit U.S. Dollars. From YouTube, which has announced that users will receive revenue according to the popularity of the video they post, to Google AdSense, which derives revenue on a per-click basis, the micro-commodification of the Internet is progressing to the point where society can efficiently and profitably trade in fractions of pennies. As a policy matter, the tax law should recognize the economic reality of these micro-transactions while avoiding spoiling the efficiencies created through plummeting transaction costs.

Leanda Lederman, the author of the article Stranger Then Fiction: Taxing Virtual Worlds discussed above, has suggested elsewhere that rather than including Second Life activity in the income tax, “the better result is to tax sales within Second Life (for Lindens).” While this may eventually be the best solution, it also implicates complicated issues as to whether requiring Linden Lab—a company that makes a point to take a hands-off approach—to withhold taxes from or to issue transaction records to millions of users will stunt the growth that Second Life is currently witnessing. This is an important question that merits further analysis.

Finally, and most unfortunately, this paper failed to provide a detailed analysis of how one measures basis in Second Life. Beyond the key operational limitations analyzed above, this is the next most important issue that could drastically affect how to think about the taxation of Second Life. Whether in the context of everyday users claiming hobby losses, active businesses claiming expense deduction, division of profits among in-world partnerships, or taxation of foreign businesses effectively connected to the U.S., the ability to account for basis will dictate what methods of taxation are plausible.

Regardless of these uncertainties and despite the assertions by Congress’s Joint Economic Committee that “taxing transactions that occur within virtual economies . . . would be a mistake,” it clear that it is only a matter of time before the wealth generated in Second Life (or its technological progeny) will be sufficiently great that Congress is passing virtual-world tax legislation and tax lawyers are specializing in the virtual world sections of the Internal Revenue Code. The implications this could have on currently untaxed income like frequent flyer miles and casino chip will have to be left for another paper. From The Taxation of Virtual Worlds: Understanding Theories of Taxation Through an Analysis of the Second Life Economy by Tim Miano.

The Relationship Between Price & Utility - Tim Miano

2. The Creation of Price Through Weighted Preferences

Previous analysis indicates that it is possible to maximize relative utility in certain circumstances with no information other than the disparately ranked preference sets of two individuals. Taking that conclusion as true, one can begin to understand the relationship between utility—measured in terms of wealth, consumption, and income­—and exchange. From a neoclassical perspective, exchange is possible when individuals recognize that they have disparate preference sets, each individual controls the means to satisfy the other’s need, and both recognize the other’s control. In the discussion of controlled and uncontrolled means above, control meant that an individual could realize utility from one half of a binary need, and which half depended entirely on which was higher ranked. In the context of exchange, control also is determined from the perspective of a second individual. That is, A controls the means to satisfy B’s preference if for some binary need, B will realize the utility from one half of the need according to some arrangement within A’s preference set.

For example, suppose that A can get apples from a tree but that B has no way to get apples other than through A’s consent. Suppose further that B has a preference set of getting an apple from A > not getting an apple from A. If A has a preference set of giving apples > not giving apples, then A will give B an apple and maximize B’s utility. However, if A prefers not giving apples > giving apples, then the lower half of B’s binary preference set will be met. In either case, B will realize one of the preferences from his binary need, and which one he realizes turns exclusively on A’s preference set. Thus, A controls the means to satisfy his own need (getting and giving v. not getting and giving) as well as B’s need (receiving v. not receiving). Notice that if A’s preference is entirely independent of anything that B can affect, then receiving an apple is an uncontrolled need with respect to B. However, if B can affect A’s preference set such that A’s preference to give an apple can turn on B’s effects, then receiving an apple is a controlled preference with respect to B. In that case, giving or not giving is a controlled need with respect to A, and receiving or not receiving is a controlled need with respect to B. In this situation exchange is possible.

Recall that, so long as fulfilling one individual’s preference set does not rearrange another’s preference set, then all thing being equal, no matter where those preferences lay in A and B’s larger preference set, if one must satisfy a need for both A and B, then it will always maximize utility to satisfy the higher ranked preference of both A and B for any pair of disparately ranked preferences (presuming no transaction costs). More clearly, when one has to satisfy some preference of both A and B, utility is always maximized by giving A one apple and B one banana with respective preference sets (1, 3) and (4, 1). This principle also holds when A controls the means to satisfy one of B’s needs and B controls the means to satisfy one of A’s needs. That is, so long as fulfilling one individual’s preference set does rearrange another’s preference set, then all thing being equal, no matter where those preferences lay in A and B’s larger preference set, it will always maximize utility for A to satisfy B’s preference and for B to satisfy A’s preference when those preferences are disparately ranked by A and B. Thus, when A controls one banana, B controls one apple, and A and B have respective preference sets of (1, 3) & (4, 1), ceteris paribus, utility is always maximized when A and B exchange their apple and banana. This is the abstracted version of what economic means when it refers to “gains from trade.”

Notice however, that if A controls one banana and B controls nothing, then once again, there is no way to tell if a transfer would be utility maximizing, even on a relative scale. Similarly, if A controls three bananas and B controls one apple, while both A and B would harvest utility when exchanging one for one, two for one, or three for one as compared to not exchanging at all, there is no way to tell which outcome is maximizes total utility because there is no common unit to measure A and B’s respective utility. Nevertheless, when A controls three bananas and B controls one apple, receiving one or two bananas for one apple increases utility for B, giving one banana for one apple increases utility for A, and giving two bananas for one apple decreases utility for A as compared to one trade. So if A and B cannot divide the apple or bananas into pieces, then one and only one exchange will take place. However, there is a point between A giving one banana and A giving two bananas where A continues to increase more utility than she loses when receiving an apple (i.e. she maintains positive diminishing returns). If A and B were able to divide their fruit into pieces, then given A and B’s preference sets, B could successfully insistent he receive up to 1.2 bananas in exchange for his apple, leaving A with one apple and 1.8 bananas. This outcome allows both A and B to realize the greatest amount of utility given each other’s preference sets, and is referred to as a Nash Equilibrium.

These principals give rise to a theory of price. In this case, A has bananas but prefers apples, making her a banana seller and an apple buyer. Because A prefers apples to bananas at a ratio of 1/3, the price of one of A’s bananas is anything greater than 1/3 of an apple. Thus, for any individual, the minimum offering price is the ratio of any two weighted preferences within a preference cluster where the numerator is the need that the individual wants satisfied through another’s control and the denominator is the controlled need the individual is offering to satisfy another’s need. Conversely, the price of B’s apple is anything greater than 1/4 of a banana, or to leave things in terms of A, B is a banana buyer and an apple seller, which means than B is willing to pay anything less than an apple for a 1/4 of a banana. Therefore, there is a price range in the banana market of 1/4 – 1 apples, and both A and B will harvest utility from any sale in this price range. As noted, given A and B’s preferences, a sale of 1 apple for 1.2 bananas maximizes utility for both A and B, so the final market price of banana will be 5/6 apples, which properly falls within the price range. From The Taxation of Virtual Worlds: Understanding Theories of Taxation Through an Analysis of the Second Life Economy by Tim Miano.

The Neo-Classical Economics of Second Life - Tim Miano

B. What Are Virtual Worlds and What Does It Mean that Virtual Worlds Have Economies?

One of the most important and interesting aspects of virtual worlds such as Second Life is the depth and sophistication of the economies that develop among the users. Perhaps surprisingly, the economies of these virtual worlds frequently satisfy all the fundamental characteristics that neoclassical economic theory demands in the real world. First, the virtual items possessed by users—essentially the actualization of computer software—are no different than any other real-world goods. Users are human beings with real-world and virtual-world needs, and the properties of some of these items satisfy some of those needs. As in the real world, users are aware of the causal relationship between attaining the virtual good and satisfying a need, and users have ways of accessing these goods and retaining control over them. Most importantly, virtual goods are scarce, making them “economic goods” no different than real-world economic goods. This last point is especially true in Second Life, where, unlike other virtual worlds, all the virtual goods are created by the users themselves. “Well over 99% of the objects in Second Life are user created.”

But these virtual items are not merely economic goods. They are economic goods within an interactive environment that satisfies principles of exchange. Different users own different virtual goods and have unique subjective needs, which allow them to reverse value one other’s goods. As users recognize that others have these disparate needs and perceive that if they could trade they would receive a net benefit, the only additional element necessary for exchange is a mechanism for excluding others from using the good without permission. Like the real world, virtual worlds solve this problem by maintaining a system of property rights over virtual goods. Whether users create new goods, receive free goods, or trade others for goods, users hold virtual-world property rights for each of these virtual possessions—a right defined by the ability to exclude and to transfer that ability to another user. Thus, all of the necessary elements for bargained-for positive sum exchange of economic goods exist within Second Life.

These two characteristics, virtual economic goods and virtual environments that foster exchange, are not surprising. Indeed, the economic properties of these virtual goods are equally present in a computerized version of the board game Monopoly. Most people would agree that Monopoly money, helpful as it may to buy Park Place or pay the Luxury Tax, has no value outside of the well defined parameters of its game environment. However, several unique features—now norms within virtual worlds like Second Life—have distorted traditional demarcations of value, wealth, and trade. As noted, users have the ability to barter with each other for virtual items and trade these items among themselves. Users can sell items to each other using this currency in place of bartering. Unlike Monopoly, however, real-world systems of trade such as eBay and PayPal allow virtual-world users to auction/sell the rights to virtual goods or the right to an account that holds virtual goods for real-world currency. These items are subsequently transferred within the virtual world. Additionally, just like Monopoly, most virtual worlds like Second Life have their own form of currency. But perhaps most surprisingly, either through the companies themselves or through sophisticated virtual-world entrepreneurs, some virtual worlds including Second Life have currency exchanges where users can trade real-world currencies for virtual-world currency and vice versa. This means that all currency, goods, and services within the virtual marketplace have a corresponding real-world monetary value.

The implication of this real-world valuation of virtual-world goods is that users can participate in the virtual world for the purpose of creating real-world wealth. As such, there are implicit incentives within this system for users to participate in the activities that are wealth maximizing. Therefore, unlike Monopoly or other virtual-world games that may nevertheless have internal economies, virtual worlds such as Second Life take on the unique and dynamic ability to satisfy a whole range of real-world needs in ways that have never been done—needs that are measured in U.S. Dollars. From The Taxation of Virtual Worlds: Understanding Theories of Taxation Through an Analysis of the Second Life Economy by Tim Miano.

A Survey of the Legal Constraints on Geospatial Technology by Tim Miano

The Rise of Little Brother: A Survey of the Legal Constraints on Geospatial Technology by Tim Miano

Introduction:

Since George Orwell first published his now infamous dystopia novel 1984, “Big Brother” has become the paradigm of government feared by the public. Every day a poster of an enormous face with the slogan “BIG BROTHER IS WATCHING YOU” greets the story’s protagonist. He trudges to his apartment where an obligatory “telescreen” continuously spouts propaganda, and through which the Thought Police monitor the actions of the citizenry. Although the technology has changed, the model of an all-knowing all-watching government has not. From chasing Will Smith to assisting James Bond, today’s Big Brother employs real-time satellite feeds that remotely read body temperature and triangulate on which floor of a building the hero is hiding. Interestingly, this accurately portrays some of the technological capabilities that a government could employ to monitor certain individuals. However, affirming the pop culture vision of Big Brother is not the goal of this article. In fact, the opposite is true.

At least in the United States, Orwell’s vision of a monolithic state has always been constrained by Articles I – III segregating power between the branches of government and the Fifth Amendment placing procedural safeguards between the state and the citizenry. Conceptually though, it is not clear that even without these legal protections, any state could achieve the opaque, paternalistic monitoring this vision fears. The technology that provides the state with the power to watch—computer networking, satellite imaging, and mass communication—is the same technology that allows governments to be watched by its own citizens (or at minimum the citizens of other nations). The Big Brother paradigm is fundamentally flawed because it assumes the state can eliminate transparency, or at least keep all of its secrets. The purpose of this article is to examine the rise of Little Brother—or to be precise, Little Brothers—and the implications therein.

This discussion will be limited to remote sensing technology (i.e. satellite imaging). The author hopes to use this technology as a vehicle to draw out some of the more interesting flaws in the Big Brother paradigm, and show how the information free market—rightly or wrongly—allows each the citizen to keep a watchful eye on government activity. Because this article is meant to be academic—analyzing the legal framework and implications of geospatial technology—and not an attempt at dystopian fiction, the analysis will refrain from wildly creative ‘what ifs.’ Instead, the article will examine the rights, duties, and limitations between the U.S. government, its commercial sector, and its citizenry to record, access, and distribute this type of data using real examples. Given the historical roots and current ties of the applicable U.S. legal structure to international laws of space and the laws of war, this discussion will take into account certain global rights and duties as well.

Part I will provide background for the state of geospatial technology and will provide some of the high profile examples of its use by the public. Part II will examine the international and domestic legal framework through which the nations and the private sector operate satellites used in remote sensing. Parts III and IV will examine the policing powers the United States can exercise to prevent or limit the dissemination of sensitive information. Part III will discuss the First Amendment rights individuals have to broadcast potentially compromising data and the limitations the U.S. government can place on those individuals. Part IV will apply the laws of treason and espionage to public use of this technology and examine whether under the same or similar facts to some of the high profile examples, how and whether the U.S. government could hinder or criminally prosecute the actions of Little Brother. Each Part will consider some subset of the rights and duties of three groups: the U.S. government, the private companies who gather and supply the data, and the individuals or groups that use or publish this data.

Virtual Worlds & Second Life - Tim Miano

PART I: Introduction to Virtual Worlds & Second Life

In order to study the novel legal ramifications of Second Life, one must have a basic understanding of its parameters and nomenclature. Second Life is an Internet-based virtual world first developed by Linden Lab in 2003. Users within Second Life, known as residents, interact within the computer simulated environment via avatars. Avatars are customizable three-dimensional graphical representations of humanoids. More clearly then, the Second Life software acts as a gateway and provides a three-dimensional forum that enables users to interact with each other through motional avatars. This platform creates a sophisticated level of a social network interactivity combined with general aspects of the Metaverse, or the meta-universe, that exists through the instantiation of an Internet-based virtual reality. The stated goal of Linden Lab is to create a world like the Metaverse: a user-defined world of general use in which people can interact, play, do business, and otherwise communicate.

A. An Overview of the Development and Content in Second Life

Second Life is frequently clustered with massively multiplayer online games, such as World of Warcraft or EverQuest, because the software provides a graphical interface and permits user interactivity that appear quite similar to these games. However, Second Life is not a game as it lacks scores, winners/losers, levels, a defined objective, or other such traditional parameters that characterize an activity as a game. Instead, at its inception, the world within Second Life was analogous to an undeveloped tract of land offering little more than open space, which has since been developed with whatever residents want for themselves or for which there is a market. Second Life residents visit this virtual world almost as if it were a real place, exploring what others have created, meeting other residents, socializing, participating in individual and group activities, and buying items (virtual property) and services from one another. Thus, while Second Life is not exclusively a social networking site like MySpace, a user driven commercial forum like eBay, a currency exchange like Citibank, a game like EverQuest, or a encyclopedia like Wikipedia, Second Life contains aspects of all of these things. Given the success of these services to satisfy certain human needs and the ability of residents to create real-world wealth by satisfying the needs of residents, it is not surprising that modified facets of these services make their way into Second Life.

This point draws out one of defining characteristics of Second Life. Namely, besides the open land and the basic parameters/limitations/rules of the environment, all of the content is user generated. (“Well over 99% of the objects in Second Life are user created.”) Using open access software, Second Life computer protocol, and three-dimensional modeling tools, any resident can build virtual buildings, landscape, vehicles, furniture, machines, games, people, and generally anything (referred to here as “items”) to use or to sell. Residents can incorporate various graphics, animation, and sound tools to create elaborate, farcical, or realistic content. It is this method of generating content that has given rise to the elaborate system of internal (as opposed to legally enforceable) property rights found in Second Life—one of the necessary conditions for a viable system of exchange. The legal status of the property right is unclear and will be examined in the context of taxation in greater detail in Part III below.

As an introductory matter, under Linden Lab’s Terms of Service agreement, any resident who creates an item retains copyrights in that item. Thus, from the perspective of the virtual-world resident the item is like personal property, but from the perspective of the real-world user the item is like duplicable software and more analogous to intellectual property. For a particular item then, users have some flexibility in how they may exercise their property rights. For example, the user who creates an item can limit it to behave like personal property by labeling it as a “no copy.” This means that a subsequent owner cannot reproduce, but may use, the underlying computer code, raising issues of use rights verses ownership rights. “No mod” on the other hand means that the owner may not modify the item’s characteristics, much like closed source software which is supposed to prevent hacking and customization—creating a more complex hierarchy of use rights. Finally, an owner of an item can label it “no trans,” which disallows transfer of ownership to another resident. Most importantly, all of these limitations can spring upon transfer. That is, creators or current owners can set these rights for future owners, much like land use covenants or servitudes. From a legal perspective then, any piece of property within Second Life can possess a wide array of property rights borrowing from real, personal, and intellectual property that remains, more or less, user-defined.

Introduction to Taxing Second Life - Tim Miano

Introduction:

A virtual world is a computer simulated environment in which human users interact with each other via graphical representations of themselves. Second Life is an Internet-based virtual world developed and released by Linden Lab in 2003. Other popular examples of virtual worlds include massively multiplayer online games such as World of Warcraft, which boasts more than 8 million users, and EverQuest, which as early as 2002 was estimated to have the 77th largest GDP in the world (between Bulgaria and Russia). Typically, virtual worlds appear similar to the real world, with constraints such as gravity, topography, locomotion, and communication.

One of the most important and interesting aspects of virtual worlds such as Second Life is the depth and sophistication of the economies that develop among the users. In fact, some virtual worlds, including Second Life, have currency exchanges where users can trade real-world currencies for virtual-world currency and vice versa. This means that the currency, goods, and services within the virtual-world marketplace have a corresponding real-world monetary value. The implication of this real-world valuation of virtual-world goods is that users can participate in the virtual-world activities for the purpose of creating real-world wealth. As such, there are implicit incentives within this system for users to participate in the activities that are wealth maximizing.

The overarching purpose of this work is explore the federal income tax consequences of the creation of Second Life—a virtual world where real people can engage in behavior constrained only by the time and effort of the users who wish to have a medium for a particular activity. Because it has developed the most mature systems of property rights, trade, and fungibility of wealth, and because it has been designed intentionally to be a more-or-less unregulated three-dimensional free market, Second Life is the focus of this work. Note, however, that much of the discussion also applies to the many other virtual worlds on the Internet, some of which currently boast millions more users and much larger internal economies than Second Life.

This work will proceed in three major parts. Part I will introduce the basic terminology and boundaries of Second Life and virtual worlds in general. It argues that the goods and services in Second Life posses all of the same economic characteristic as real-world goods and services, and that it is improper to dismiss Second Life as no different than the video games that have, in part, given rise to the technology that makes Second Life possible. Part II will introduce some basic concepts for income taxation and briefly examine the Haig-Simons definition of income. It will examine Haig’s original work that gave rise to this definition, and then, using introductory economic concepts develop the fundamental framework underlying the modern definition of income that Haig and Simons failed to explain. The purpose of this inquiry is to establish that as a purely theoretical matter, the wealth generated from the activities in Second Life is indistinguishable from those in the real world. Finally, having established that Second Life wealth is taxable income under the theoretical premises for § 61, Part III will analyze the activities in Second Life under the current tax law. First it will examine whether the three primary operational limitations that currently exists in the tax code would exempt Second Life from taxation. Second, using partnership tax law as a model, it will explore whether the efficiencies and substantial reduction in transaction costs that are unique Second Life too easily create accidental tax liability such that the current tax law fails to incorporate operational limitations special to Second Life. This work concludes that under the current law the users of Second Life would properly be subject to some form of taxation for their in-world activities. It also briefly speculates at some policy reasons for why the government should delay taxing those activities despite the applicability of the tax law and lists some important tax questions left unanswered by this work. From The Taxation of Virtual Worlds: Understanding Theories of Taxation Through an Analysis of the Second Life Economy by Tim Miano.

Articles Edited by Tim Miano

ARTICLES EDITED:

John Yoo, The Terrorist Surveillance Program and the Constitution, 14 Geo. Mason L. Rev. 565 (2007), available at http://www.law.gmu.edu/gmulawreview/issues/14-3/Documents/Yoo.pdf.

Michael Sinclair, Precedent, Super-Precedent, 14 Geo. Mason L. Rev. 363 (2007), available at http://www.law.gmu.edu/gmulawreview/issues/14-2/documents/SINCLAIR.pdf. (Abstract here)

Jarrod Wong, Umbrella Clauses in Bilateral Investment Treaties: of Breaches of Contract, Treaty Violations, and the Divide Between Developing and Developed Countries In Foreign Investment Disputes, 14 Geo. Mason L. Rev. 135 (2006), available at http://www.law.gmu.edu/gmulawreview/issues/14-1/documents/WONG-FinalFormatted.pdf.

About ~Efficient Happiness, a Tim Miano project

~Efficient Happiness is an approximation of a website that I have wanted to create for some time. As an avid reader, watcher, viewer of Internet media, I am constantly coming across content that I would like to share with others. Some services like Del.icio.us and Digg allow web surfers to tag and share content. Unfortunately, these services are not as expansive as I would like in two ways. First, frequently I only want to share some small part of someone’s work. Second, I want to string ideas together with a common theme using text, pictures, and video. After two years of testing other methods, I decided to just make my own website so that it would be closer to my vision.

Because "blog" connotes that I primarily intend to publish my own content, it seems inappropriate to label ~Efficient Happiness as blog. For now, I will call it an "eclection." Perhaps “archive” or “collection” or “edited content & link depot” would be better suited, but from what I can tell, other people on the Internet are not approaching media in this way, so it seems that what I am trying to accomplish currently lacks suitable terminology. If anyone out there has any suggestions, please let me know.

I try to attribute all material on this site to its original source using both title and hyperlink. In addition, I personally ping the links to all the material that I excerpt so that the host of that material will know I am using it and can contact me if they are dissatisfied with my use. At this time I receive no monetary benefit from anyone for the content herein, and despite any arguments I might have supporting fair-use under copyright law, I have a blanket policy to remove any content to which any original author objects.

A few points on style. I readily admit that some of these conventions run counter to some custom that the blogosphere has adopted. But because I am trying to do something novel in form, and not just substance, some of this custom does not lend itself. I hope this explanation will help to create adequate transparency such that viewers do not assume that I am the original author. First, I have begun to use block quotes for all excerpted material. Unfortunately, this merely creates a uniform indentation in the post, which visually defeats the purpose. As such, I also include introductory and conclusory ellipses. Second, given the fluctuating nature of Wikipedia as a tool and its novelty as a resource, I don’t “cite” to Wikipedia by name. Instead, I hyperlink to the page from which material came. Third, because one of my primary goals is to string together content from various sources to confer common ideas, I use “---” between excerpts. Fourth, I do lightly edit and rearrange some material without using internal brackets or ellipsis as a proper editor would. I feel that this is reasonable since I use hyperlinks to the original source and not footnotes. That is, any third party who wants to formally cite any content they find on my webpage is directed to the original and, if following proper citation guidelines, would use that original material to quote the author. Thus, the risk of formally misquoting an author is minimal, while the post preserves readability for the normal user. Finally, although I rarely post my own written material, when I do, I try to cite myself as the author.

I hope you enjoy the content on this site. I am always open to comments and suggestions. By ~Tim Miano