Brian Leiter's Law School Reports

Some questions for Professor Benjamin H. Barton about his use of IRS data to estimate solo practitioner incomes (Michael Simkovic)

After Tuesday's post explaining why IRS schedule C data dramatically underestimates incomes for solo practitioners and other sole proprietors, Professor Benjamin H. Barton emailed to indicate that his views remained unchanged and he did not intend to respond beyond his previous comments on Professor Stephen Diamond's blog.  Barton's comments did not address many of the issues I raised. 

On Wednesday, I asked Professor Barton to consider the following questions:

1) Do you think that 20 million or so U.S. small business owners are living below the poverty threshold for a 2 person household?

2) Do you think the IRS is wrong about its own data and schedule C does not in fact understate net income?  Why do you think that you understand IRS data, IRS enforcement capabilities, and the level of tax evasion better than the IRS?

3) Do you think that everyone who files schedule C has no other sources of income?

4) Do you think that Treasury and JCT estimates of tax expenditures are way off and exclusions and deductions from tax concepts of income are negligible?

5) If apples to apples comparisons using schedule C data show that legal services sole proprietorships are more profitable than 97 percent of sole proprietorships, is that something you should mention?  Would you at least agree that using schedule C data for legal services and census data for everyone else is a methodological error?

Professor Barton has not yet responded.

UPDATE:

Aug. 11, 2016. Professor Barton responded without specifically answering the questions above, but generally conceded that IRS data is problematic.

Aug. 15, 2016.  I replied to Barton.

How much do lawyers working in solo practice actually earn? (Michael Simkovic)

In 2015, Professor Benjamin Barton of the University of Tennessee estimated for CNN.com, and Business Insider that attorneys working in solo practice earn an average of slightly less than $50,000 per year.  Barton made similar estimates in his book, “Glass Half Full.”  Professor Stephen Diamond of Santa Clara argues that solo incomes are quite a bit higher. (Barton responded in the comments section).

There is little doubt that solo practitioners typically earn substantially less than lawyers working in large Wall Street Law firms.  However, a closer reading of the Internal Revenue Service data on which Barton relies and Census data both suggest that solo practitioner average (mean) annual earnings are likely closer to $100,000.  

 

    I. Average (Mean) Incomes of Lawyers: Census Income Data vs. IRS Schedule C Net Income Data

According to the U.S. Census Bureau’s American Community Survey, average (mean) total personal income for lawyers who are “self employed, not incorporated” (a proxy for those in small legal practice) was around $140,000 in 2012 and 2013.  For those who were self-employed, incorporated (a proxy for those who are owners of larger legal practices) average total personal income was around $180,000 to $190,000.  These average figures include those working part time.  Restricting the sample to those working full-time increases average earnings for “self employed, not incorporated” lawyers to around $160,000 to $165,000 and for the “self-employed, incorporated” lawyers to $185,000 to $200,000.

Barton based his earnings estimates on average “net income” data from the Internal Revenue Services Statistics of Income for Non-farm Sole Proprietorships  for “Legal Services (NAICS Code 5411)”.  This data is based on Schedule C of form 1040, which is used to calculate one of several sources of income on an individual tax return (“Business Income or Loss”). 

Looking at the same IRS schedule-C net-income data for all non-farm sole proprietorships and applying Barton’s reasoning suggests that in 2013, 24 million American small business owners earned an average (mean) income of $12,500.  This is barely above the poverty threshold for a 1 person household, and considerably lower than average (mean) earned income figures for all Americans reported by the U.S. Census’s American Community Survey (around $47,000 including only those who are employed in some capacity, and $22,000 averaging in everyone—children, the retired, and those not in the work force).

 

    A. IRS Schedule C Data Is Biased Downward:

What explains the large discrepancy between low IRS sole proprietor net income data and higher Census earnings data—for lawyers and for everyone else?  There are several problems with IRS sole proprietor data that are likely to lead to dramatic underestimation of individual earnings. 

 

        1. IRS Schedule C Does Not Report Important Sources of Income

First, IRS Schedule C data does not capture all individual earnings.  It captures only one category of earnings—“Business Income and Loss”—and excludes other extremely important sources of earnings—notably Wages and Salaries, which are reported on a separate line on form 1040.

Many schedule C filers are gainfully employed—and indeed, derive most of their income from salaries and wages—but maintain a side business to earn extra income

 

        2. Taxpayers Understate Business Net Income on Schedule C

Second, the IRS has long recognized that small business owners dramatically underreport their revenue and overstate their business expenses to reduce their tax liability.  According to one widely cited IRS estimates, sole proprietors typically understate their net income—the number used by Barton—by 57 percent.   This IRS estimate has been widely cited by the Government Accountability Office and leading scholars of tax compliance such as University of Michigan Economist Joel Slemrod.

Salaried employees in large established businesses with electronic payroll systems cannot evade taxes on their W-2 incomes because their employers report their compensation to the Internal Revenue Service and other government agencies.  Salaried employees also typically have relatively few opportunities to claim business deductions for personal expenses because they do not have sufficient business income to offset those expenses and the IRS is likely to categorize their activities as “hobbies.”

By contrast, sole proprietors do not have to contend with third-party reporting and therefore have ample opportunity for tax evasion.  The problem of small business owner tax evasion has gotten worse over time as the IRS’s enforcement resources have diminished relative to its responsibilities.  Both the probability of detection and the penalties for tax evasion are very low.[1]  IRS SOI data is based on a sample of unaudited returns.

It seems likely that many small practitioners systematically underreport their net income on schedule C.  Lawyers’ sophistication and familiarity with the legal system may suggest that lawyers are relatively well equipped to reduce their tax bills legally, for example by claiming deductions.  In 2013 IRS average business receipts for legal services sole proprietorships was around $116,000.  Deductions and exclusions averaged around $67,000.  There were 70,000 returns for sole proprietors in legal services with no net income that still generated an aggregate of $1.6 billion in revenue.  To the extent that claimed deductions or exclusions really reflect personal consumption or clever tax planning, business receipts may provide a better guide to true income than taxable net income.  

 

      3. IRS Income Measures Exclude Some Income by Design

Third, and relatedly, there are differences  between Income Tax and Census definitions of income that will tend to make Adjusted Gross Income and Taxable Income lower than Census income.  These differences generally reflect tax policy choices to encourage certain activities or reduce the tax liability of certain constituencies. Unlike Census definitions of income, taxable income will exclude or deduct contributions to self-employed retirement plans and some IRA contributions, self-employed health insurance, contributions to medical savings accounts, student loan payments up $2,500 per year (with a phase-out as income increases), tuition and fees up to $4,000 per year, and so on.  IRS definitions of net income change with changes in tax law, and therefore are not consistent over extended periods of time.

 

        4. “Legal Services” Includes Businesses other than Law Firms

Fourth, as noted by Professor Stephen Diamond, “Legal services”(NIACS code 5411) includes not only “Offices of Lawyers (NAICS code 54111)” but also notaries (NAICS code 54112), title searchers, and other law related businesses (NAICS codes 541191 and 541199 ) typically not staffed by lawyers and that are typically less lucrative than legal practice. The IRS has confirmed by email that its data includes these categories.  However, the IRS does not have more granular information that would enable it to determine what fraction of “Legal Services” in its data constitutes “Offices of Lawyers.” [2]

 

    B. Census Data Is Probably Approximately Right:

There are strong reasons to believe that IRS sole proprietor data systematically and dramatically understates individual income.  Are there reasons to believe that Census data systematically overstates individual income for lawyers?  Probably not.

 

        1. Census Data Underestimates Incomes for Highly Educated, High Income Workers

Individuals have no financial reason to overstate or understate their incomes to the Census.  Innocent mistakes can and do happen.[3] Studies that have matched individual social security earnings records to self-reported earnings on the Census suggest that highly educated, high income workers tend to under-report their incomes to the Census.[4]  This may be because they forget about bonuses, or they report their take-home pay rather than their pre-tax income.  The Census also uses imputation and top-coding procedures that reduce average income for those who are highly educated and in high income professions.  (Frank McIntyre and I briefly discussed these issues in the 2013 draft version of The Economic Value of a Law Degree).

 

        2. Census Data Probably Includes Some Practitioners Who are in Small Practice Groups Rather Than Solo Practice

The biggest problem with Census ACS data for solo practitioners is that self-employed lawyers are not perfect estimates for solo practitioners, because “incorporated” and “not incorporated” are not clearly defined.  Even “not incorporated” could include some owners of practices larger than sole proprietorships.  But the other available categories, the number of lawyers in each category for class of worker, and incomes in each category suggests that the self-employed, not incorporated category maps on reasonably well to small practitioners.

 

    II.  After The JD Data Is Early Career and Looks At Medians Rather Than Means

After the JD suggests that median (not mean) income for solo practitioners is around $50,000 to $80,000, and that only around 10 percent of law graduates are solo practitioners.  By contrast, Professor Barton has suggested that a very large proportion of lawyers are in solo practice and described solos as the legal profession’s “middle class.”[5]

After the JD probably identifies solo practitioners well, but there are two important issues to consider.  First, the median income is likely substantially lower than the mean income.  The IRS data used by Barton and the Census data discussed above both refer to mean income.  Second, After the JD reports on individuals in the first 3 to 12 years after graduation—a relatively early stage in their careers when incomes will be relatively low.  Earnings will likely increase later in their careers, as may the proportion of solo practitioners.

 

    III. Apples to Apples Comparisons within IRS Data Suggest that Even Lawyers who are Solo Practitioners are Doing Relatively Well Financially

Differences across data sources highlight the importance of apples-to-apples comparisons within a single data source and context.  Unfortunately, Barton mixed and matched different data sources, comparing low estimates from IRS data for legal services sole proprietorships to higher estimates from other sources for workers other than lawyers. 

Comparing across sole proprietorship categories using only the (flawed) IRS schedule C data shows that legal services ranks near the top of industries based on average net-income.  In 2013, Legal services trailed offices of doctors, dentists, and securities brokers, but was well ahead of sole proprietorships in most other industries, which accounted for more than 97 percent of sole proprietorships.  This ranking matches Census and BLS earnings data, which shows lawyers typically trailing doctors, but leading most other occupations.

In other words, lawyers remain among the highest paid occupations and legal services appear to be among the most profitable small businesses. 

 

[1] The probability of a tax evader being detected is low.  The IRS audits less than 1% of tax returns and only around 2% to 3% of Schedule C tax filers.  Audits will sometimes fail to uncover tax evasion even when it is present. 

In addition to low probability of detection, the penalties for non-compliance are also typically low.  Filers who the IRS believes have underpaid can typically resolve the matter by paying roughly what they owe.  The IRS will sometimes accept partial payments as settlement and will sometimes impose penalties that are relatively modest (considering the extremely low probability of detecting tax evasion).

Criminal investigations and jail time for tax evasion on income earned legally are virtually non-existent.  In 2013, there were around 145,000,000 annual individual income tax return filings and 24 million flings by sole proprietors—including millions of tax evaders by IRS estimates.  The IRS only investigated around 2,000 legal source tax crimes.  Only around 1,100 of these lead to incarceration.

One unpublished working paper suggests that lawyers may be more tax compliant than most because of reputational concerns.  Others might suggest that lawyers are not optimally situated to underreport revenue because they tend to be paid by check rather than in cash.  Payment by check makes under-reporting more challenging than payment by cash, but still makes underreporting easier than payment by credit card.  Anecdotally, solo practitioners sometimes settle bills through payment in kind.  In To Kill a Mockingbird the fictional country lawyer Atticus Finch accepts farm products as payment from Walter Cunningham.  In more modern, urban, and non-fictional settings, I’ve known lawyers who have accepted high-end furniture, meals at a client’s restaurant or tailoring at a client’s shop, and even a collection of star trek videos (in the days before Netflix).

Legally, payment for services in goods or other services generates taxable income the same as payment in cash, but barter often goes unreported.  And solo practitioners can aggressively claim deductions even when they cannot underreport revenue. 

Changes in tax enforcement and tax compliance over time mean that biases in IRS data will not be consistent across extended time periods.

[2] Within Census data, Offices of Lawyers are the overwhelming majority of the legal services category.  However, the IRS sole proprietorship data may have a different mix—IRS data suggests far more legal services sole proprietorships than several Census studies.  This may be because Census data for establishments generally includes only establishments with Federal Tax Identification Numbers (EINs), but schedule C does not necessarily require an EIN. 

[3] Intentionally providing false information to the Census is in theory punishable by a small fine, although in practice this is virtually never enforced.

[4] Social security records are thought to be useful because they are tied to third party employer reporting on W-2s.  They could overlook non-W-2 wage and salary income, or contain errors.

[5] ABA data suggests that a substantial proportion of individuals with law licenses are solo-practitioners—perhaps around 37 percent as of 2005.  Census data suggests a lower proportion of lawyers are solos—around 20 percent in 2005 and around 15 percent more recently.  (This is lawyers whose class of worker was “employed, not incorporated”).  The ABA may use a broader definition of “lawyer” based on holding a license to practice law or having a (possibly out of date) entry in a registry; Census only includes as lawyers those who classify their occupation as lawyer each year.  Many individuals with law licenses either work primarily in another occupation or are not actively participating in the workforce.  These nominal lawyers may be classified by the ABA as solo practitioners, inflating solo practitioner counts.

 

UPDATE:

July 28, 2016. I asked Professor Barton a series of questions about his use of IRS data.

Aug. 11, 2016. Professor Barton responded, generally conceding that IRS data is problematic.

Aug. 15, 2016.  I replied to Professor Barton.

Annals of "bullshit" rankings

Rankings are fun, sure, but it's good to figure out wheter the metric means something (anything!) lest one produce nonsense.  Case in point:  ranking law reviews by Google Scholar h-indices.  The problem (we've encountered it in philosophy in the past, but now everyone there knows Google  Scholar is worthless for measuring journal impact) is that there is no control for the volume of publishing by each journal, so any journal that publishes more pages and articles per year will do better than a peer journal with the same actual impact that publishes fewer articles and pages.

UPDATE:  In the case of philosophy, Synthese was the number 1 journal in "impact" according to the nonsense Google number--this was obviously ludicrous, as everyone in academic philosophy knew.  But Synthese also publishes five to ten times as many articles per year as the actual leading journals in the field.  One philosopher adjusted the results for volume of publication, and lo and behold, Synthese rank fell dramatically.

Most-Cited lists: what's coming

Two more subject-matter areas:  Family Law and Legal Ethics/Legal Profession/Professional Responsibility.  And then a list of schools by the per capita rate at which their tenured faculty made one of the many most-cited lists.   I should have these lists out by mid-August at the latest.

Lateral hires with tenure or on tenure-track, 2015-16

THIS IS THE LAST TIME I AM MOVING THIS TO THE FRONT FOR THE PAST HIRING SEASON--THE 2016-17 INITIAL LIST WILL APPEAR HERE ON AUGUST 1

These are non-clinical appointments that will take effect in 2016 (except where noted); I will move the list to the front at various intervals as new additions come in.   Recent additions are in bold. Last year's list is here.   

 

*Edward Afield (tax) from Ava Maria School of Law to Georgia State University.

 

*Lisa Alexander (corporate, contracts, housing & urban development law) from the University of Wisconsin, Madison to Texas A&M University.

 

*Mark Alexander (constitutional law, law & politics) from Seton Hall University to Villanova University (to become Dean).

 

*James Anaya (international human rights) from the University of Arizona to the University of Colorado, Boulder (to become Dean).

 

*RonNell Anderson (constitutional law, First Amendment, media law) from Brigham Young University to the University of Utah.

 

*Margo Bagley (patents, international patent law) from the University of Virginia to Emory University.

 

*Craig Boise (tax, international tax, corporate tax) from Cleveland-Marshall College of Law, Cleveland State University to Syracuse University (to become Dean).

 

*Zack Buck (health law) from Mercer University to the University of Tennessee, Knoxville (untenured lateral).

 

*Michael Cahill (criminal law) from Brooklyn Law School to Rutgers University (as Co-Dean).

 

*Dale Carpenter (constitutional law) from the University of Minnesota to Southern Methodist University.

 

*James Coleman (energy law) from the University of Calgary to Southern Methodist University (untenured lateral).

 

*Nicolas Cornell (contracts, law & philosophy) from the Wharton School at the University of Pennsylvania to the University of Michigan (law) (untenured lateral) (starting in fall 2017).

 

*Eric Dannenmaier (environmental law) from Indiana University, Indianapolis to Northern Illinois University (to become Dean). 

*David Fagundes (property) from Southwestern Law School to the University of Houston.

 

*Joshua Fischman (law & economics, empirical legal studies) from Northwestern University to the University of Virginia.

 

*Michael Frakes (health law, innovation policy) from Northwestern University to Duke University.

 

*Susan Franck (international economic law & dispute resolution) from Washington & Lee University to American University.

 

*Shubha Ghosh (intellectual property, law & technology, antitrust) from the University of Wisconsin, Madison to Syracuse University.

 

*James Grimmelman (intellectual property, cyberlaw) from the University of Maryland to Cornell Tech (New York City) and Cornell University (Law, Ithaca).

 

*Joanna Grossman (family law, gender and the law) from Hofstra University to Southern Methodist University.

 

*Grant Hayden (corporate governance, voting rights, labor law) from Hofstra University to Southern Methodist University.

  

*Carissa Byrne Hessick (criminal law, legal ethics) from the University of Utah to the University of North Carolina, Chapel Hill.

 

*Andrew Hessick (administrative law, constitutional law, federal courts, remedies) from the University of Utah to the University of North Carolina, Chapel Hill.

 

*David Hyman (health law, insurance law) from the University of Illinois to Georgetown University.

 

*Garry Jenkins (law & philanthropy, corporate governance, leadership studies) from Ohio State University to the University of Minnesota (to become Dean).

 

*Janine Kim (criminal law, race & the law) from Marquette University to Chapman University.

 

*Renee Knake (legal ethics, constitutional law) from Michigan State University to the University of Houston.

 

*Sarah Lawsky (tax, law & philosophy) from the University of California, Irvine to Northwestern University.

 

*Andrew Lund (corporate, securities) from Pace University to Villanova University.

 

*Fatma Marouf (immigration law & clinic) from the University of Nevada, Las Vegas to Texas A&M University.

 

*Thomas Mitchell (property, land use, remedies, rural development) from the University of Wisconsin, Madison to Texas A&M University.

 

*Camille Nelson (critical race theory, criminal law & procedure) from Suffolk University to American University (to become Dean).

 

*Erin O'Hara O'Connor (conflicts, dispute resolution, law & economics) from Vanderbilt University to Florida State University (to become Dean).

 

*Angela Onwuachi-Willig (family law, employment discrimination, critical race theory) from the University of Iowa to the University of California, Berkeley. 

 

*Jordan Paradise (food & drug law, administrative law, biotechnology law) from Seton Hall University to Loyola University, Chicago.

 

*Matthew Parlow (land use, urban planning & policy, sports law) from Marquette University to Chapman University (as Dean).

 

*Gregg Polsky (tax, corporate finance, corporate law) from the University of North Carolina, Chapel Hill to the University of Georgia.

 

*Lawrence Ponoroff (commercial law) from the University of Arizona to Michigan State University (to become Dean).

 

*Nicholson Price (patents, health law) from the University of New Hampshire to the University of Michigan, Ann Arbor (untenured lateral).

 

*Greg Reilly (patents, intellectual property) from California Western School of Law to Chicago-Kent College of Law (untenured lateral).

 

*Edward B. Rock (corporate) from the University of Pennsylvania to New York University.

 

*Amy Schmitz (aribtrarion, consumer law, contracts) from the University of Colorado, Boulder to the University of Missouri, Columbia. 

 

*Beth Simmons (international law, international human rights) from Harvard University (Government Department) to the University of Pennsylvania (Law & Political Science).

 

*Bruce P. Smith (legal history) from the University of Illinois to the University of Denver (as Dean).

  

*Jane Stapleton (torts, tort theory) from the University of Texas, Austin to Christ's College, Cambridge (to become Master)

 

*Alex Stein (evidence, torts, medical malpractice, criminal law, legal theory) from Cardozo Law School to Brooklyn Law School.

 

*Elizabeth Trujillo (international trade) from Suffolk University to Texas A&M University.

 

*Kristen van de Biezenbos (energy, oil & gas, environmental) from Texas Tech University to the University of Oklahoma, Norman (untenured lateral).

 

*Steve Vladeck (federal courts, national security law, constitutional law) from American University to the University of Texas, Austin.

 

*Gina Warren (energy law, oil & gas law) from Texas A&M University to the University of Houston

 

*Melissa Wasserman (patents, intellectual property, administrative law, torts, innovation law and policy) from the University of Illinois to the University of Texas, Austin.

 

*Ellen Yaroshefsky (legal ethics) from Cardozo Law School to Hofstra University.

 

*Taisu Zhang (legal history, comparative law) from Duke University to Yale University (untenured lateral).

Revenge porn law introduced in Congress

An important milestone; law professor Mary Anne Franks (Miami), the primary author of the bill, is quoted in the article.

(Thanks to Jason Walta for the pointer.)

UPDATE:  An op-ed by Prof. Franks about the law.  If there is, in fact, a successful First Amendment challenge to the law, it would just be a further indication of how wrong U.S. free speech doctrine is in important respects.

Ten Most-Cited Antitrust Faculty, 2010-2014 (inclusive)

  Once again, this draws on the data from the 2015 Sisk study:    

Rank	Name	School	Citations	Age in 2016
1	Herbert Hovenkamp	University of Iowa	1070	68
2	Daniel Crane	University of Michigan	400	46
3	William Kovacic	George Washington University	390	64
	Joshua Wright	George Mason University	390	39
5	Michael Carrier	Rutgers University (Camden)	370	47
6	Christopher Leslie	University of California, Irvine	340	52
	Daniel Rubinfeld	New York University	340	71
8	C. Scott Hemphill	New York University	310	43
9	Spencer Waller	Loyola University, Chicago	280	59
10	Timothy Muris	George Mason University	250	67
		Runners-up for the top ten
	Jonathan Baker	American University	240	61
	Fred McChesney	University of Miami	240	68
	William Page	University of Florida	240	65
		Other highly-cited scholars who work partly in this area
	Mark Lemley	Stanford University	2400	50
	Louis Kaplow	Harvard University	1150	60
	Einer Elhauge	Harvard University	680	55
	George Priest	Yale University	570	63
	Keith Hylton	Boston University	440	56

 

Obligations of law faculty to disclose research supported by those with a stake in the findings?

Prof. Jeff Sovern (St. John's) writes:

I have been wondering about the extent of law professors’ ethical obligations to disclose when their research has been supported by a grant from a group with a stake in the findings, and because you are the de facto moderator of the law professor village square, I wondered if you would consider posting the item below to your blog and seeking comment. I apologize for its length.

 

A grant that results in the publication of a law review article or similar publication should be acknowledged in the article, but what about later work in the same general area that espouses a policy position consistent with what the grantor would have wanted? That issue is germane to a 2013 article in The Nation, The Scholars Who Shill for Wall Street which criticized academics (notably, George Mason’s Todd Zywicki) for failing to disclose in papers, congressional testimony, speeches, op-eds, etc. compensated work for the financial industry.  The AALS has been rather vague on this subject, but here’s what it said in its Statement of Good Practices by Law Professors in the Discharge of Their Ethical and Professional Responsibilities: “Sponsored or remunerated research should always be acknowledged with full disclosure of the interests of the parties. If views expressed in an article were also espoused in the course of representation of a client or in consulting, this should be acknowledged.” It’s not at all clear to me that the conduct described in The Nation article violated that policy.

 

My own concern is more personal.  My law school (St. John’s) accepted a grant from an organization with ties to a particular industry.  My co-authors and I conducted a survey financed by this grant (we had to purchase a software license, compensate those who completed the survey, and so on) and published a law review article about our findings.  We had complete control over the survey and what we wrote about our findings and the grantor did not comment on them; in all respects, its behavior was exemplary.  We acknowledged the funder in the article.  Later, I wrote some op-eds about our work, and acknowledged the grantor again.  Still later, I wrote op-eds about the broader subject, giving no more than a sentence to our research, or not mentioning it at all. Do I have an obligation in the later op-eds to mention the grantor?  Would readers want to know that my law school accepted money from the grantor which supported my research?  If your answer is no, do you see anything wrong with the conduct described in The Nation article?  If you answer is yes, would it be different if the funder were not associated with a particular industry or point of view?

 

Perhaps the AALS would consider updating and elaborating on its statement.  It might be a good project for professors specializing in professional responsibility. When the AALS re-evaluates a school for membership every seven years, does it inquire into compliance with this aspect of its Statement of Good Practices?  Should it? 

Good questions, I've opened it for comments.  (Submit your comment only once, comments are moderated, and may take awhile to appear.)

Hiring committees can announce themselves...

...and their curricular priorities here.

A first sign of trouble with the new Elsevier-owned SSRN

Uh-oh.

UPDATE:  More details from IHE, definitely take a look.