Wednesday, August 08, 2007

Dishonest Tax Rhetoric, Part 3 of 3

In the last two days, I've created an admittedly arbitrary list of rhetorical claims that are often used in U.S. political discussions about taxes. Entirely unscientific in both origin and design, the list purports to rank the degrees of dishonesty that animate some of the more outrageous assertions by those who can broadly be described as "anti-tax," which in the current climate breaks down almost entirely on partisan lines. (Republicans eagerly assert their opposition to taxes as a categorical matter; Democrats too often agree that taxes are generally bad but defend taxes on the basis of a combination of fiscal discipline and targeted policy objectives.)

The two lucky winners so far: 3rd Place went to the claim that allowing the Bush tax cuts to expire would constitute the Biggest Tax Increase Ever, and 2nd Place went to the proponents of a national sales tax who insist on presenting the tax rate under their plan (which is artificially low for several reasons, not the least of which is that they assume that tax evasion will cease entirely, even after eliminating the IRS and dumping sales tax enforcement on the states) in a way that no normal person would expect.

The big winner will not surprise those who know me: The Death Tax. There are two separate arguments for calling the estate tax the death tax, one technical and one practical. Both are completely wrong.

The technical argument is that the estate tax cannot be assessed until a person dies. The tax, therefore, is a tax on death. "You don't die, you don't pay the tax." Notwithstanding the humorous notion that this is exactly the kind of incentive that we should want to build into the tax code (one more reason not to die), the fact is that we do not identify taxes on the basis of their triggering event. The income tax can be assessed annually (either on a calendar year or fiscal year basis) or at shorter or longer intervals. No matter the interval, it is still an income tax because it is a tax on income. If you are paying an income tax on a calendar year basis, you do not pay tax until Dec. 31 ends. Even so, it is an income tax and not a "New Year's Eve Tax."

Property taxes are not identified by the date that they are paid, either, but by what is being taxed (the value of property). Sales taxes are assessed on the dollar amount of certain purchases of goods, which at least means that the thing that's being taxed (consumption) and the date that it is being taxed (upon purchase) can coincide; but the term sales tax refers to the fact that we're computing the tax based on the amount of the sale, just as we assess income taxes on the amount of income.

The practical argument goes something like this: "Sure, technically this is not a tax on death itself. But come on, it's a tax on death! It just makes sense to call it a death tax." Leaving aside the lack of actual content to this argument, the point seems to be that we should ignore consistency or history and simply indulge our desire to focus on death as the triggering event.

If we're allowed to be practical in this sense, though, this opens up the field to all kinds of practical observations. That estate taxes are currently paid by fewer than 1% of all decedents' estates suggests that the current use of the term estate tax is quite accurate in the connotative sense -- only people with "estates" pay the estate tax. (I had a student who once argued that the term "estate tax" had been invented by "a bunch of liberal lawyers sitting in a room somewhere trying to make the tax sound like it would only apply to rich people." Sometimes being a professor means exercising incredible self-control.) While not everyone who earns an income pays income tax every year, yet we still call it an income tax, as a practical matter most people will earn income and pay income taxes at many points in their lives. Practically speaking, almost no one who dies will leave behind an estate tax liability.

"Death tax" thus wins the gold because it loses either way. Either it focuses on something that is irrelevant to the designation of all other taxes, or it highlights the least important (and most misleading) practical fact about the estate tax. It is a focus-group tested invention that too many politicians use to distort the debate. It takes the award for most dishonest tax rhetoric. Unfortunately, the competition is fierce, and the game is never over.


DavidFL10 said...

I agree completely.

Tam Ho said...

What's perhaps even scarier is the Republicans' success at defining the terms of the debate. Thus, as David Cay Johnston points out in his book, Perfectly Legal, even the journalist David Gregory uses the term "death tax" uncritically. For a more recent example, one need go back no further than the most recent Republican debate, in which George Stephanopolous desribed the "fair tax" using, among other fallacies, the 23% figure:

"And the Iowa Republican Party has said the most important economic reform Congress can enact to win the fight against poverty is the fair tax. For our viewers, I want to explain what the fair tax is. It would eliminate the income tax, estate tax, payroll tax and capital gains tax. It would eliminate all those and replace it with a 23 percent sales tax. That’s the fair tax."

So much for the liberal media.

And here are a few more gems from the ensuing discussion:

"I absolutely support the fair tax. And part of the reason is, the current system is one that penalizes productivity . . . And what the fair tax does, it ends the underground economy. . . No more illegals, no more gamblers, prostitutes, pimps and dope dealers will be able to escape the tax code. " - Huckabee.

"There are a lot of features that are very attractive about a fair tax. Getting rid of the IRS is something we’d all love." - Romney

This exchange between Guiliani and Romney is particularly precious:

G: "Eliminate the death tax."

R: "Of course. Of course."

G: "And that should be eliminated immediately. It makes no sense at all. In 2010, the death tax is going to go to zero percent. And then it’s going to go to 55 percent in 2011. You do not want to be on a respirator in 2010."

It would require great effort even for a Jonathan Swift to improve upon what is already actually being said by these people. After all, how do you satirize satire?

I'll give Guiliani credit, though, for at least acknowledging the following about the "fair tax":

"It would be too complex to get there. And somebody would have to show me how we’re going to make that transition. And, also, the thought that there wouldn’t be an IRS with the fair tax -- well, who is going to administer the sales tax? And who’s going to administer the people that are exempt from the sales tax? And who is going to administer what items might be exempt from the sales -- maybe food would be exempt from the sales tax."

andy grewal said...

Uh, doesn't the Code itself repeatedly refer to "death taxes"? What's so misleading about calling something a "death tax" if Congress also calls it that? Blame Congress, not commentators.

Neil H. Buchanan said...

No, the tax that people are calling the Death Tax is officially called the Estate (and Generation-Skipping Transfer) Tax. Moreover, the point is that many members of Congress (that is, virtually all Republicans) are joining the commentators in mislabeling the Estate Tax. They're all wrong, though it's possible that some might simply have been taken in by the big lie.

Tam Ho said...

Andy, you're really making two arguments. First, you're saying it's not misleading. It is. It's misleading because it creates the impression that it will affect everybody, when in truth it affects only something like 1 or 2% of the population. Congress's use doesn't make it not misleading.

Your second argument is that Congress's use of the phrase excuses commentators' use of it. It doesn't. Even if Congress's usage defined the linguistic universe available to commentators, the IRC does refer to both the "death tax" and the "estate tax," and so there is a choice, and therefore, responsibility, in the matter.

andy grewal said...


The Code repeatedly refers to "death taxes." Maybe that is misleading (I'm no expert on the estate tax), but it nonetheless strikes me as odd to complain about people calling something the "death tax" when Congress calls it that, on occasion.

See, e.g.:

(f) Cross references.--

For special rules relating to redemption--

(1) Death Taxes.--Of stock to pay death taxes, see section 303.

26 U.S.C.A. § 302


§ 303. Distributions in redemption of stock to pay death taxes


(g) Exceptions.--This section shall not apply to--

(1) distributions to which section 303 (relating to distributions in redemption of stock to pay death taxes) applies; or

26 U.S.C.A. § 1248


§ 2011. Credit for State death taxes


(b) Computation of credit.--Subject to the limitation prescribed in subsection (c), the credit provided by this section shall be an amount which bears the same ratio to the estate tax paid (adjusted as indicated hereinafter) with respect to the estate of the transferor as the value of the property transferred bears to the taxable estate of the transferor (determined for purposes of the estate tax) decreased by any DEATH TAXES paid with respect to such estate.

26 U.S.C.A. § 2013


§ 2014. Credit for foreign death taxes


(C) Death taxes payable out of bequests.--

26 U.S.C.A. § 2106


(I) any Federal estate tax or State death tax actually recovered from the trust attributable to such property, and

26 U.S.C.A. § 2642

Neil H. Buchanan said...

"[I]t nonetheless strikes me as odd to complain about people calling something the 'death tax' when Congress calls it that, on occasion."

The "something" and the (second) "it" in that sentence are referring to the estate tax, which Congress never calls the death tax. That is, when Giuliani and Romney agree that the "death tax" should be repealed, they are talking about the estate tax. Congress does not call the estate tax the death tax, even on occasion. The code sections that you cite are referring generically to taxes levied by other jurisdictions (states, other national governments) at death -- which can include both estate and inheritance taxes imposed by those jurisdictions (and not by the federal government). Section 2642(l), which you cite, makes this clear: "[A]ny Federal estate tax or State death tax ... "

If it were up to me, I would not use that terminology even there. But it is simply wrong to say that Congress has referred to the federal estate tax as the death tax as a way of excusing the blatant political distortion at play.

Unknown said...


That rebuttal seems to boil down to objecting that capitalization is dishonest. To summarize your argument:

A) Congress calls the tax the "Estate (and Generation-Skipping Transfer) Tax." That is its proper title.

B) As you admit, Congress also refers to similar taxes, including estate taxes levied in other jurisdictions, as "death taxes," despite your deep personal misgivings about this habit. (This does not, it seem, trouble Congress very much.)

[B.1) Contrary to the assertion of your post that "we do not identify taxes on the basis of their triggering event," it appears that the Code does identify taxes in just this way, at least if those taxes arise in foreign jurisdictions. So much for the technical dishonesty.]

C) Thus, the Estate (and Generation Skipping Transfer Tax) is akin to what the code would call a death tax if it were levied elsewhere, or by a state. In every real sense, it's a tax that falls into the category (when it needn't be more specifically referenced) of death taxes. But it's horribly dishonest, indeed the Most Dishonest Claim In Tax Rhetoric, to call it The Death Tax.

Personally, I find the use of "X is dishonest" when an author means "I disagree with X" to be the most dishonest rhetorical claim in tax analysis, but admittedly only in a very recursive sense.

andy grewal said...

"But it is simply wrong to say that Congress has referred to the federal estate tax as the death tax as a way of excusing the blatant political distortion at play."

Even assuming that hair-splitting is appropriate, does that really warrant the argument that saying that the estate tax is the death tax is the greatest travesty and the most dishonest instance of tax politicking? Surely there must be much better examples than this.

If "death taxes" is misleading, fine. As I said, I'm no expert on the estate tax. But this amount of complaining over the fact that people generically refer to the federal estate tax as the "death tax" strikes me as odd, seeing that Congress itself refers to taxes imposed at death by states/foreign countries as death taxes, even if those respective political subdivisions might not.

Tam Ho said...

What if we did this?

Proposition A:
"Calling the Estate Tax the 'Death Tax' is dishonest because is misleads an ordinary person about the breadth of its effect."

Proposition B:
"Calling the Estate Tax the 'Death Tax' is dishonest because Congress never refers to it by that name."

Proposition C:
"Congress never refers to any Estate or Inheritance Tax by that name."

What if I just assert Proposition A, without necessarily asserting Proposition B and C? In that case, do you think your arguments still apply? Because that is the central point of the argument. So I take it that you also find it pretty clear that "death tax" creates the the false impression that it applies to everyone, given that you don't address this central point.

I think your arguments are actually motivated by the notion those who use it aren't culpable, not that it isn't misleading. You may be thinking, "Well, that's just it's name, and those who use it are just following in the footsteps of those who came before them, including the very same body that created the tax! What's so CULPABLE about that?"

Why would Congress's use of a clearly misleading phrase justify or even excuse its repetition by those who should know better?

Unknown said...


I don't think you gain anything by dropping two portions of the argument.

There are reasonable arguments to be made that "estate tax" might be, in some ways, more precise than "death tax," although this is an open question. Despite Neil Buchanan's suggestion, it's obvious that naming taxes according to their triggering events are not per se inappropriate. (As even he concedes, the Code does this.)

The question then becomes what is "misleading" and what is defining terms of debate. I find it a bit bizarre to suggest that "death tax" is misleading but "estate tax" is not: after all, neither term specifically defines the estates that will be brought within the scope of the tax. (If I died right now, my estate would be worth little, and certainly not enough to tax. I would still have an estate, however, just as I have a death. So, at least in my case, neither term is particularly more accurate than the other.)

The term "death tax" does, of course, have a more emotive quality. It places the tax man at the bedside of a grieving family, after all. You may or may not think this is important, or what the debate should focus on. There are those, however, who think that death is not an appropriate taxable event. For those people to argue that the tax is a death tax--and to try to convince others of the same--is not "dishonest." They may not focus on the part of the tax that you, personally, care about, but oddly enough, those folks are under no moral duty to make your argument for you. Quite the opposite, actually.

Personally, I think referring to the Estate Tax as the Death Tax is a bit hokey. Nevertheless, there's a fair distance between hokey and dishonest, and the latter isn't an accusation that should be tossed around lightly. For one thing, it normally serves as a substitute for decent critical thinking. (As I said above, neither "death tax" nor "estate tax" are particularly descriptive. A reasonable argument might be that one is more precise than the other. By labeling the latter 'dishonest,' however, you relieve yourself of the burden of having to make the argument: the other side is merely morally reprehensible.)

Michael C. Dorf said...

Neil's central point in the column is that the term "death tax" is deliberately misleading because it implies that death triggers a tax on assets for most Americans, when it doesn't. That seems irrefutable. Indeed, the people who branded "death tax" did so deliberately with the intention of changing public opinion. If Congress were to amend the U.S. Code tomorrow to substitute the term "death tax" for "Estate (and Generation-Skipping Transfer) Tax," wherever the latter appears, that would not undermine Neil's argument. It would simply mean that the misleading statement had been made ex cathedra.

And that might well be worse. As a matter of observed fact, the use by Congress of a term for propagandistic purposes results in the adoption of that term by the media and the public. Thus, courts, journalists and academics must refer to the "Anti-Terrorism and Effective Death Penalty Act" even though most of the Act's provisions are simply about limiting the ability of federal courts to grant relief to state prisoners, without regard to whether such denials of relief have anything to do with terrorism or making the death penalty more "effective." Likewise, the "Partial Birth Abortion Ban Act" meant that the term "partial-birth abortion" became part of the standard vocabulary. The most egregious example in recent memory is the USA Patriot Act, an appellation that implies that those who oppose its substance are unpatriotic. Likewise "death tax" aims not only to convey the impression that the tax applies widely but also to portray supporters of the tax as heartless, extracting lucre even from grieving widows and orphans.

Michael C. Dorf said...

By "column" I meant "post." "Column" was not used for propagandistic purposes.

andy grewal said...

""death tax" is deliberately misleading because it implies that death triggers a tax on assets for most Americans, when it doesn't. That seems irrefutable."

Actually, it's easily refuted. There's nothing "deliberately misleading" about using "death tax" as shorthand for the collection of wealth transfer taxes -- even Congress does it. And, the statutes that refer to "death tax" go far back -- Congress was referring to "death taxes" well before those taxes became controversial. "Death tax" wasn't plugged in the code as a disguise, the way PATRIOT might have been. The phrase "death tax" is simply a useful shorthand.

To say that anyone who uses the phrase "death tax" is "deliberately misleading" other people amounts to nothing more than a useless ad hominem attack. If I write a legal memo analyzing the tax laws and reference "death taxes," I'm not trying to mislead the partner or client examining the issue. The suggestion that one's use of that phrase necessarily makes him a liar is offensive.

Look, no one doubts that some/many/most (take your pick) of those who lobby for death tax repeal use misleading tactics, such as suggesting that the death tax breaks up small family businesses. I have no problem with academics refuting that tired notion. But the argument that the use of "death tax" necessarily makes one an evil bastard is annoying and should not be made, particularly since Congress, courts, tax lawyers and the public have used it for a long time.

Benjam said...

mike's summation of neil's argument is that the term death tax is misleading because most estates fall under the unified credit and, therefore, are not taxed. one might argue that the term "capital gains tax" is similarly misleading because most americans dont pay that tax either. the difference is this: not all americans reap capital gains, but of those who do, ALL of them pay the tax. "capital gains" are always taxed. the nyc and nys transfer taxes are the same. all transfers (with modest exceptions) are taxed. in contrast, all americans die, but only a tiny fraction see a tax on their estate. so death isnt really being taxed. they should keep the unified credit at one million dollars and call it "the million dollar inheritance tax."

for those interested, the broader argument about false labelling in politics is explored in great deal by Hacker & Pierson in OFF CENTER.

Tam Ho said...


To be precise, an ad hominem attack is one that attempts to refute an argument by discrediting the person making the argument, WITHOUT addressing the substance of the argument. An example of an ad hominem attack would be a propensity inference on character, for example, and hence its general exclusion under the rules of evidence. But, of course, not every attack on credibility is an ad hominem attack. Suppose a prosecutor presents a witness to contradict a defendant's purported alibi. That would certainly impeach the defendant's credibility, but it is hardly an ad hominem attack. Rather, it is a perfectly legitimate and logical attack on the substance of the defendant's claims.

Neil's post was not an ad hominem attack because he presented logical, substantive reasons for why the term "death tax" is misleading to the general public - reasons that had nothing to do with the character of the persons using the phrase. That lawyers may use it all the time does not change this fact, nor does it make lawyers liars. The context of the discussion is the phrases's use in American political life.

So you are exactly right to note that some/many/most lobbyists - and I would include politicians - use the phrase in a deliberately misleading way. That's just the central point of Neil's post.

That the phrase is capable of non-misleading use by some other group of speakers - e.g., lawyers - in another context - e.g., writing a legal memorandum - is irrelevant to Neil's central point.

As a final observation, note that the "holding," if you will, of Neil's post requires him to take no position on the underlying issue of whether we should have an estate tax. Indeed, an integrous backer of repeal of the tax might very well employ Neil's argument and say to his friends, "Come on guys, we have legitimate reasons for urging repeal of the Estate Tax; we don't need to use a phrase that we know will create a false impression among our constituents."

Tam Ho said...

To clarify, I meant to say that the central point ("holding") of Neil's post does not require him to take a position, either way, on the underlying issue of whether to have an estate tax. (Not that it requires him to abstain from taking a position.)

Unknown said...

"Neil's central point in the column is that the term "death tax" is deliberately misleading because it implies that death triggers a tax on assets for most Americans, when it doesn't. That seems irrefutable."

You know, assuming that an argument is irrefutable is pretty lazy. If I were to say the following, I'm pretty certain that you'd not just roll over and concede my point. Indeed, Neil would probably call the following attempt "dishonest," and I might even score in his top ten! (Not that I'm calling Dorf dishonest. As I've said, I don't think it's a very practical method of debate.)

Neil's central point in the column is that the term 'estate tax' is deliberately misleading because it implies that possession of an estate triggers a tax on assets for most Americans, when it doesn't. That seems irrefutable.

The implicit argument that Neil is making is that most decedents do not have estates. I've recently been going through the checklist of tasks one must do to join the Delaware Bar, one of which involves making a visit to the Register of Wills and going through several estates. I can state with considerable confidence that the number of decedents not subject to a death tax is almost identical to the number of estates not subject to an estate tax, because almost all decedents have an estate, even if there isn't much in it. Alternative, one can say that the majority of deaths or estates are subject to a death tax, even if the effective tax rate is zero, which is how I would conceptualize it, but the argument is largely the same. The idea that the term "death tax" is inherently misleading may only be maintained by arguments that apply with equal force to "estate tax." Or are you proposing that Neil's gold medal should have gone to two winners?

(I'm assuming that Neil's use of scare quotes around "estate" is a method of getting around this, though exactly what that argument might be is a bit unclear, so I cannot address it.)

Which leads one to tam's point that Neil's argument is not an ad hominem attack. Neil hasn't actually provided any argument for why the term is "dishonest." His technical argument is simply wrong as a matter of fact: he concedes that although he doesn't think one should call an estate tax a death tax, the Code does do this as a matter of fact. His practical point is not so much a matter of argument than personal preference: he thinks that one aspect of a tax is important, and others stress another aspect. Until Neil becomes some kind of moral arbiter accepted by society as a whole, that doesn't make an argument. Neil's personal preference in terminology shouldn't be the basis for maligning the character of his opponents.

This is, of course, the problem. One might make an argument that specific people using the term "death tax" have done so in a way that is misleading. Neil sort of makes this argument for his "silver medal" when he talks about a 23% tax rate. One can say that switching to tax-inclusive rates is misleading if custom is to use tax-exclusive rates. (The rest of his argument sort of trivialize his opponents by addressing straw men, but we'll leave that aside.)

Neil's argument with his "gold" medal, however, is far broader. He's putting forward the idea that the term "death tax" is inherently misleading, and any who would use it must do so dishonestly. I don't think he's actually provided anything close to an actual argument for this, nor do I think that most death tax proponents actually use the term in the manner he suggests. He's merely put forth what he--and Dorf--think is irrefutable. (My time at Columbia taught me that anyone holding an "irrefutable" argument probably hasn't tried to refute it very hard at all.)

Perhaps the argument isn't strictly an ad hominem. It is, however, a spectacularly weak basis on which to question an opponent's moral character, so I doubt that the label matters much. I wouldn't hold my head high by making an argument "good enough to avoid the latin."

Unknown said...

Likewise "death tax" aims not only to convey the impression that the tax applies widely but also to portray supporters of the tax as heartless, extracting lucre even from grieving widows and orphans.

As a bit of an aside, I was unaware of a provision in the Estate Tax that exempts from its reach assets that would transfer to widows or orphans who express a suitable degree of sorrow at their loss. I'll admit to a non-encyclopedic knowledge of the Code, but it's not come up in any reading I've done.

(If one were very technical, an inheritance tax does that, and an estate tax extracts lucre from the estate before it's transferred, I suppose. But I don't see the crux of Dorf's argument as "The estate tax takes from an estate before it passes. Only an inheritance tax would be heartless!")

Hence, the only way that the statement "The estate tax does not take from grieving widows and orphans" would be true is if it is assumed that the heirs of a wealthy estate cannot, by virtue of their wealth, actually be grieving. Such a supposition is the only way that the statement "The estate tax takes from grieving widows and orphans" can, as a matter of fact, be dishonest.

Dorf may well think that the fact that the orphans and widows are wealthy makes their grieving unimportant, or at least less important, when one considers the imposition of tax. Such is a valid position and an honest position. It is not unassailable, however, and one who disagrees with it is neither misleading nor dishonest.

Unknown said...

I'm sure all these people who are duped into believing they'll be taxed on death will be equally surprised to learn that they aren't paying taxes on their income when they earn it despite the substantial sum being withheld from their paychecks each week, which they cannot invest or otherwise earn interest on before their employers turn it over to the government at the end of the year. Perhaps the Dishonest Tax Rhetoric series requires a part 4.

Anonymous said...

免費A片, ut聊天室, AV女優, 美女視訊, 免費成人影片, 成人論壇, 情色交友, 免費AV, 線上a片, 日本美女寫真集, 同志聊天室, 聊天室交友, 成人文章, 成人圖片區, 色情網站, 辣妹視訊, 美女交友, 微風成人區, 色美媚部落格, 色情影片, 成人影片, 成人網站, 免費A片, 上班族聊天室, A片,H漫, 18成人, a漫, av dvd, 一夜情聊天室, 微風成人, 成人圖片, 成人漫畫, 情色網, 日本A片, 免費A片下載, 性愛, 成人交友, 嘟嘟成人網, 嘟嘟成人網, 成人貼圖, 成人電影, 成人, 中部人聊天室, 080中部人聊天室, 成人貼圖, 成人小說, 成人文章, 成人圖片區, 免費成人影片, 成人遊戲, 微風成人, 愛情公寓, 成人電影, A片, 情色, 情色貼圖, 情色文學, 做愛, 成人遊戲, 成人影城, 色情聊天室, 色情小說, 一葉情貼圖片區, 情色小說, 色情, 寄情築園小遊戲, 色情遊戲, 成人網站, 麗的色遊戲, 色情網站, 成人論壇, 情色視訊, 情色電影, aio交友愛情館, 言情小說, 愛情小說, 色情A片, 情色論壇, 自拍, 癡漢, , 俱樂部, 豆豆聊天室, 聊天室, 色情影片, 視訊聊天室, 免費視訊聊天, 免費視訊, 視訊交友90739 情人視訊網影音視訊聊天室 免費視訊聊天室 視訊聊天 視訊交友 美女視訊 視訊美女 視訊 免費視訊 免費視訊聊天 視訊聊天室 辣妹視訊 一夜情 色情a片 aio交友愛情館 情色電影 情色視訊 色情遊戲 色情 情色小說 一葉情貼圖片區 色情小說 色情聊天室 情色交友 成人論壇 成人網站 色情網站 情色論壇 小高聊天室 女同志聊天室 6K聊天室 080苗栗人聊天室 080聊天室 聊天室尋夢園 UT男同志聊天室 男同志聊天室 尋夢園聊天室 UT聊天室 聊天室 豆豆聊天室 A片 成人電影 成人貼圖 嘟嘟成人網 美女交友 本土自拍 成人交友 成人影片

Anonymous said...

It is the knight noah which makes me very happy these days, my brother says knight gold is his favorite games gold he likes, he usually knight online gold to start his game and most of the time he will win the knight online noah back and give me some cheap knight gold to play the game.

Anonymous said...

酒店喝酒,禮服店,酒店小姐,酒店經紀,制服店,便服店,鋼琴酒吧,兼差,酒店兼差,酒店打工,伴唱小姐,暑假打工,酒店上班,日式酒店,舞廳,ktv酒店,酒店,酒店公關,酒店小姐,理容院,日領,龍亨,學生兼差,酒店兼差,酒店上班,酒店打工,禮服酒店,禮服店,酒店小姐,酒店兼差,寒暑假打工,酒店小姐,台北酒店,禮服店 ,酒店小姐,酒店經紀,酒店兼差,寒暑假打工,酒店小姐,台北酒店,禮服店 ,酒店小姐,酒店經紀,酒店兼差,寒暑假打工,酒店小姐,台北酒店,禮服店 ,酒店小姐,酒店經紀,酒店兼差,寒暑假打工,台北酒店,禮服店 ,酒店小姐,酒店經紀,酒店兼差,寒暑假打工,酒店小姐,台北酒店,禮服店 ,酒店小姐,酒店兼差,寒暑假打工,酒店小姐,台北酒店,禮服店 ,酒店小姐,酒店經紀,酒店兼差,寒暑假打工,酒店小姐,台北酒店,禮服店 ,酒店小姐,酒店經紀,酒店兼差,打工,酒店小姐,台北酒店,禮服店 ,酒店小姐,酒店經紀,酒店兼差,寒暑假打工,酒店小姐,台北酒店,禮服店 ,酒店小姐,酒店經紀,酒店兼差,寒暑假打工,酒店小姐,禮服店 ,酒店小姐,酒店經紀,酒店兼差,寒暑假打工,酒店小姐,禮服店 ,酒店小姐,酒店經紀,酒店兼差,寒暑假打工,酒店小姐,禮服店 ,酒店小姐,酒店經紀,酒店兼差,寒暑假打工,酒店小姐,禮服店 ,酒店小姐,酒店經紀,酒店兼差,寒暑假打工,酒店小姐,禮服店 ,酒店小姐,酒店經紀,酒店兼差,寒暑假打工,酒店小姐,經紀 彩色爆米花,經紀人 彩色爆米花,酒店傳播,酒店經紀 彩色爆米花,爆米花,童裝,童裝拍賣,童裝大盤,童裝寄賣,童裝批貨,酒店,酒店,童裝切貨,酒店,GAP童裝,酒店,酒店 ,禮服店 , 酒店小姐,酒店經紀,酒店兼差,寒暑假打工,招待所,

Anonymous said...

酒店喝酒,禮服店,酒店小姐,制服店,便服店,鋼琴酒吧,兼差,酒店兼差,酒店打工,伴唱小姐,暑假打工,酒店上班,日式酒店,ktv酒店,酒店,酒店公關,酒店小姐,酒店兼差,酒店上班,酒店打工,禮服酒店,禮服店,酒店小姐,酒店兼差,寒暑假打工,酒店小姐,台北酒店,禮服店 ,酒店小姐,酒店經紀,酒店兼差,寒暑假打工,酒店小姐,台北酒店,禮服店 ,酒店小姐,酒店經紀,酒店兼差,寒暑假打工,酒店小姐,台北酒店,禮服店 ,酒店小姐,酒店經紀,酒店兼差,寒暑假打工,台北酒店,禮服店 ,酒店小姐,酒店經紀,酒店兼差,寒暑假打工,酒店小姐,台北酒店,禮服店 ,酒店小姐,酒店兼差,寒暑假打工,酒店小姐,台北酒店,禮服店 ,酒店小姐,酒店經紀,酒店兼差,寒暑假打工,酒店小姐,台北酒店,禮服店 ,酒店小姐,酒店經紀,酒店兼差,寒暑假打工,酒店小姐,台北酒店,禮服店 ,酒店小姐,酒店經紀,酒店兼差,寒暑假打工,酒店小姐,台北酒店,禮服店 ,酒店小姐,酒店經紀,酒店兼差,寒暑假打工,酒店小姐,禮服店 ,酒店小姐,酒店經紀,酒店兼差,寒暑假打工,酒店小姐,禮服店 ,酒店小姐,酒店經紀,酒店兼差,寒暑假打工,酒店小姐,禮服店 ,酒店小姐,酒店經紀,酒店兼差,寒暑假打工,酒店小姐,禮服店 ,酒店小姐,酒店經紀,酒店兼差,寒暑假打工,酒店小姐,禮服店 ,酒店小姐,酒店經紀,酒店兼差,寒暑假打工,酒店小姐,經紀 彩色爆米花,經紀人 彩色爆米花,酒店傳播,酒店經紀 彩色爆米花,爆米花,童裝,童裝拍賣,童裝大盤,童裝寄賣,童裝批貨,酒店,酒店,童裝切貨,酒店,GAP童裝,酒店,酒店 ,禮服店 , 酒店小姐,酒店經紀,酒店兼差,寒暑假打工,招待所,酒店小姐,酒店兼差,寒暑假打工,酒店上班,暑假打工,酒店公關,酒店兼職,酒店經紀

Anonymous said... . .
[url=]puma shoes[/url]
[url=]chaussures puma[/url]
[url=]nike air max ltd[/url]

Anonymous said...

酒店經紀人, 菲梵酒店經紀, 酒店經紀, 禮服酒店經紀, 酒店兼職經紀, 便服酒店經紀, 酒店打工經紀, 制服酒店經紀, 專業酒店經紀, 合法酒店經紀, 酒店暑假打工, 酒店寒假打工, 酒店經紀人, 菲梵酒店經紀, 酒店經紀, 禮服酒店經紀, 酒店兼職經紀, 便服酒店經紀, 酒店打工經紀, 制服酒店經紀, 專業酒店經紀, 合法酒店經紀, 酒店暑假打工, 酒店寒假打工, 酒店經紀人, 菲梵酒店經紀, 酒店經紀, 禮服酒店經紀, 酒店兼職經紀, 便服酒店經紀, 酒店打工經紀, 制服酒店經紀, 專業酒店經紀, 合法酒店經紀, 酒店暑假打工, 酒店寒假打工, 酒店經紀人, 菲梵酒店經紀, 酒店經紀, 禮服酒店經紀, 酒店兼職經紀, 便服酒店經紀, 酒店打工經紀,

Anonymous said...

酒店經紀人, 菲梵酒店經紀, 酒店經紀, 禮服酒店上班, 酒店小姐兼職, 便服酒店經紀, 酒店打工經紀, 制服酒店工作, 專業酒店經紀, 合法酒店經紀, 酒店暑假打工, 酒店寒假打工, 酒店經紀人, 菲梵酒店經紀, 酒店經紀, 禮服酒店上班, 酒店經紀人, 菲梵酒店經紀, 酒店經紀, 禮服酒店上班, 酒店小姐兼職, 便服酒店工作, 酒店打工經紀, 制服酒店經紀, 專業酒店經紀, 合法酒店經紀, 酒店暑假打工, 酒店寒假打工, 酒店經紀人, 菲梵酒店經紀, 酒店經紀, 禮服酒店上班, 酒店小姐兼職, 便服酒店工作, 酒店打工經紀, 制服酒店經紀,,

Edwin said...

Buy Kamagra
Earn Google
Viagra Cialis
Cheap Kamagra
Cheap Viagra
Cheap Cialis
Make Money on Google
M65 Jacket
M65 Field Jacket
Airline Dog Carrier
Airline Dog Carriers
Viagra Cialis
Earn Google
Airline Dog Carrier
Airline Dog Carriers
Airline Approved Dog Carriers
ED Hardy Wholesale
Copy DVD Software
How to Send Fax
14k Yellow Gold
Redneck Costume
14k Gold Heart
Tandem Baby Stroller