The Code Enforcement Gestapo

WHAT IF LAW AND REASON CONFLICT?

GEORGE WILSON ADAMS CPA CPA

December 27, 2021

The Goddess of Law (Themis) arm-wrestles the Goddess of Reason (Athena.) The stakes are high, the game is dangerous, and the outcome is uncertain. Who will yield? Who will lead?

(1) WHAT’S WRONG?

Fear Lives and Thrives in Your Zip Code

Many people fear the IRS and state tax agencies. People fear being subjected to a tax audit, and having to deal with government agents pouring over their personal financial records looking for a ‘gotcha’ so they can hit you with a huge tax bill, including penalties and interest.

Recently, one of my elderly retired clients received a bill from the IRS for over $100,000, including a $20,000 penalty. The bill was completely wrong. My client, who lives on a very modest fixed income, had sold her home a year earlier and the sale was tax-free. The IRS had been given all the information it needed to know this. They didn’t do their job and treated the sale as taxable.

My client suffers from a heart condition and had to go to the emergency room for treatment as a direct result of the shock and fear caused by the erroneous IRS bill delivered to her by certified mail. It’s hard to believe, but the truth is that threatening letters can actually injure and even kill people.

But I can tell you for a fact, based on recent experience buying my own commercial office building, that there is something potentially worse than the IRS, something more intrusive, more local, more in-your-face, more hostile, and more threatening. What could be worse than the IRS? In many cases the answer is your local city code enforcement department.

Code Enforcement Horror Stories

As a practicing CPA approximately 20% of my clients are in real estate, including construction, residential and commercial rentals as well as property management. The stories I hear from them about local code enforcement issues are remarkably consistent: more often than not code enforcement officers hurt, hinder and even destroy businesses in our community, or prevent new business from moving in or getting started. I speak from experience on this subject.

Here are three horror stories which reveal the harm and destruction misguided code enforcement can impose on communities (the names of the guilty have been omitted to shield them from infamy, but not from shame. Are you paying attention Ben?)

(A) Not long ago, a church in central Maine wanted to expand its facilities inside a commercial mall. The church had been in that location for several years and was doing well. It needed additional space to accommodate more churchgoers. The city code enforcement officer blocked the expansion of the church through a zoning technicality. The church was forced to move to another city. Jobs, income, and opportunity were driven out of town. The taxpayers of this city were hit with the cost of expensive federal litigation. 

(B) Several years ago a coastal Maine town decided it was a brilliant idea to punish a small non-profit organization that was operating a famous theater that had existed since approximately 1930. This non-profit spent $150,000 on a new marquee for their theater, investing in the community. The non-profit was struggling financially and the $4,000 fine imposed by the town was devastating. The fine was assessed because certain code enforcement procedures were not followed to the satisfaction of town officials. Apparently, local code enforcement didn't like the color of the new marquee.

(C) My last horror story is the tragedy faced by the sister of my client, who attempted to open a small business in another central Maine town. The Code Enforcement Officer (“CEO”) who handled her case engaged in a disgusting practice called ‘moving the goalpost.’ The CEO gave this woman a list of tasks to complete in order for her to obtain official government permission to open her small, family business.

At great cost and effort she completed all of these tasks. When she requested her certificate of occupancy the CEO then gave her a new list of additional tasks and work. He deliberately moved the goalpost. My client’s sister ultimately decided to move forward and disregard the arbitrary and abusive manner in which the CEO was handling her case.

(2) WHY IS IT WRONG?

Law Becomes Arbitrary When it Conflicts With Reason

The rule of law is the very foundation of civilized society, just as taxes are the price we must pay for civilization. Civil order isn’t achieved by accident and freedom isn’t free. But human law can become redundant, arbitrary, and even harmful through the passage of time and changing circumstances. For example, a zoning district drawn up in 1967 may have been quite reasonable at that time while becoming arbitrary, even absurd today, almost half a century later.

All complex, rule-based systems are subject to a process of decay, growing redundancy and arbitrariness. Complex, rule-based systems get old just like people do.

For example, computer programs have a tendency to accumulate ‘old code’ that is no longer needed, is redundant, and arbitrary. Old computer code can provide a back door for hackers to break into computer systems and undermine their integrity.

Another example relates to the DNA in our bodies which provides the blueprint for maintaining health and keeping us alive. A substantial percentage of human DNA is ‘silent’, i.e., it performs no known function. Silent DNA can mutate leading to disease. Here again we see how a complex, rule-based system can accumulate old, outdated, arbitrary instructions that lead to harm.

Human law is another complex, rule-based system that has a tendency to accumulate ‘old law’ that is outdated, arbitrary and even harmful. As a CPA I see this constantly with the continuing growth of our tax laws, which grow by accretion year after year. Vast forests of trees have been cut down in order to plant ever more and more acres of law that yield a bitter harvest of unreason.

I highly recommend the 2015 book by Charles Murray which discusses many of these issues in depth: By the People: Rebuilding Liberty Without Permission.

What is Arbitrary Power?

Arbitrary power is a rule without a good reason. It’s easy to test for the presence of arbitrary power. The test is simple to perform. For any law or rule just ask one question: Why? Why does the law or rule exist in the first place? What public good is achieved or preserved by the law?

If you receive silence as the answer you will have proof the law is arbitrary because no good reason can be cited to corroborate or substantiate the existence of that particular law.

And if the answer you receive is a mere robotic, mechanical citation of the law itself, with no reference to good thinking, facts, evidence, or good judgment, then, once more, you will have proof the law is completely arbitrary.

Arbitrary power is present when reason is absent.

Law is not and never will be a good substitute for thinking and conscience.

Nor is reason an easy or automatic way to create good law. The House of Reason has many rooms, and completely rational and informed individuals may have very different views on what a law should and should not do. Good law, like reason, is hard work.

The complete absence of reason means a law is arbitrary. Law without reason is a form of tyranny; reason without law is a form of anarchy. We must constantly fight for the ideal: that law and reason walk together and stand forever at each others side, eternal allies in the search for true justice in this world. Not to do this is both a crime and a paradox.

The Danger of Arbitrary Power

Arbitrary power is profoundly contrary to our American system of limited government of checks and balances. The central idea of our system is that NO one branch or division of government acquires absolute power. This concept applies at the national, state and local level of government.

Arbitrary government is dangerous for two reasons. First, it turns government personnel into thugs - agents of arbitrary action and enforcers of unreason with reckless disregard for the harmful consequences of what they inflict on their victims. Second, arbitrary government is obviously farcical and directly undermines public respect for and confidence in the law.

Contempt for law, like the absence of law, is a very dangerous development which encourages anarchy and the rule of unreason.

Arbitrary government is a self-inflicted wound we should never tolerate. Life is already difficult enough. Should government try to improve on cancer and impose something even worse on us? Why?

Arbitrary government is an act of theft, fraud and violence perpetrated by the government against its own people. We should never tolerate such a thing.

How Can a City Succeed if its Businesses Don’t?

The manner in which code enforcement is implemented in any given community will have major implications for attracting or scaring off new business. Business owners contribute significantly to the tax base of a city, reducing property taxes on a per capita basis, and funding essential city services. Many Maine towns have an ‘anti-business’ mentality that is nothing more than folly.

Failure Is Possible: It Can Happen Here

In 1950 the city of Detroit, Michigan had a population of approximately 1.8 million. At that time, Detroit was a thriving, major American metropolis with a booming economy. In 2010 the population of Detroit had plunged to 710,000 and vast areas of the city were in ruins.

The city has gone through the humiliation of a municipal bankruptcy, the largest in U.S. history. Gestapo-style code enforcement is NOT the primary cause of the ruin of Detroit. But poor decisions by municipal officials can cause cumulative harm and damage that will weaken rather than strengthen the economic foundation of any city.

Cities can fail and it can happen right here in Maine, the same as any other place. We are not immune to failure.

What if the Law is Wrong?

For thirteen horrible years this flag represented the law which applied to millions of unfortunate people subject to Nazi rule. The greatest war in history, World War II, was fought to defeat the ideas this flag stood for, including arbitrary rule, racial hatred, and an all-powerful central government which sought to control every aspect of individual life. The definitive history of this period was written by the American journalist, William Shirer, in his classic work, The Rise and Fall of the Third Reich.

I have a favorite question I love to ask young, junior, inexperienced attorneys who have just finished law school. My question (which has been asked by others before me) is deceptively simple. FAIR WARNING: those who first read this question will be tempted to answer reflexively, without thought or consideration. The truth is that this question is surprisingly complex and profound.

Some lawyers have complained that it is unfair of me to ask them this question since, as practicing attorneys, they are considered officers of the court they serve. Nevertheless, I refuse to excuse lawyers from answering this important question. In fact, I believe no one should be allowed to become a lawyer unless they know the correct answer.

The question takes the form of a statement where I ask you to answer true or false. Here is the statement. I strongly encourage anyone who wants to tackle it to think carefully before giving an answer:

True or false and why?

Implications of Saying the Answer is ‘True’

I refer to the Gestapo in the title to this article. “Gestapo” is the German acronym for Geheime Staatspolizei (Secret State Police), a law enforcement organization formed by the Nazis on April 26, 1933. Originally led by Hermann Göring, operational control was eventually given to Heinrich Himmler, head of the SS and the death camps.

The Gestapo were reviled and detested for the particularly brutal manner in which they upheld arbitrary power throughout Nazi-occupied Europe. If you asked a Gestapo agent why he was torturing someone, why he was sending a particular man to a concentration camp, or why he was executing a particular woman, the answer would always be the same:

‘I’m just following orders. I’m carrying out my instructions. I’m obeying the law that applies in my time and place. I’m just doing my job. I’m a good German who simply follows the rules.’

During the Nuremburg War Crimes Trials held after WWII these excuses were NOT respected as a valid defense for the abuses committed by the Gestapo. The classic 1961 movie, Judgment at Nuremberg, tells this story well. I highly recommend the book, The Gestapo: A History of Horror by Jacques Delarue. Delarue was a member of the French Resistance who was arrested by the Gestapo for sabotage.

As I said above, and it bears repeating, law is not and never will be a good substitute for conscience and thinking. The judges at Nuremburg knew this. So too did the great philosophers Kant, Spinoza, and Aristotle. And so too did our own founding fathers, who overthrew arbitrary and abusive British law and replaced it with the constitutional rule of reason.

The time to fight arbitrary power is when it is small, weak, and easily defeated. A simple analogy illustrates why this is a smart strategy: if I see a small fire begin on my neighbor’s property I am not going to foolishly assume the fire will go out on its own, or that it is too small to bother me. Instead, I will call 911 and ask to have the small fire put out, before it becomes a big fire that engulfs my neighbor’s building, and then spreads to mine.

Implications of Saying the Answer is ‘False’

People are fallible and imperfect. Thus, it is completely unsurprising that something made by people, including law, will itself be fallible and imperfect. The 19th century American writer and philosopher Henry David Thoreau knew this principle well.

Thoreau is famous for writing Walden, an autobiographical account of his thoughts and experiences living alone in the woods for about two years in a cabin he built himself. He is less known for a highly influential essay published in 1849 called Civil Disobedience.

In this important essay Thoreau argued that it is the duty of every citizen to resist unjust laws. Thoreau took this principle very seriously and went much further than most of us practicing it in his personal life. In July 1846 Thoreau was arrested for refusing to pay a poll tax he regarded as unjust.  Thoreau had a famous friend, the great American writer Ralph Waldo Emerson. Emerson found out his friend Thoreau was in jail in Concord, Massachusetts, and traveled there to visit him. History (accordingly to some accounts) records the following exchange of words between Emerson and Thoreau at the jail where Thoreau was locked up:

Emerson: “Henry, what are you doing in there?”

Thoreau: “Waldo, the question is what are you doing out there?”

(Henry Thoreau and ‘Civil Disobedience’ by Wendy McElroy)

Thoreau freely chose to pay the price for breaking the law in order to publicly expose its injustice. His great essay, Civil Disobedience, has been enormously influential worldwide, and was read by Gandhi in India, Nelson Mandela in South Africa, and our own Martin Luther King.

Today, we can be sure that some oppressed or imprisoned individual in some ruthless dictatorship somewhere in the world is reading or remembering Thoreau’s famous essay and wondering how to apply it to their own circumstances. The revolutions which matter begin inside the mind. Thinking is the most dangerous and the most necessary thing in all the world.

What if Law and Reason Conflict?

What if a particular law requires us (metaphorically speaking) to jump off a cliff? Do we mindlessly and robotically obey the law or should we pause and think first? In order to answer this question correctly we must remember that law is a means to an end, not an end in itself. Law is a tool to create and preserve order and maintain civilized values.

People and society in general have a duty to resolve conflicts between law and reason. A civilized society will take steps to ensure that its laws, overall, are reasonable and not arbitrary.

There are three levels of conflict between law and reason, with correspondingly appropriate ways to resolve the conflict:

First, there are minor conflicts between law and reason, where law creates harm that is a mere nuisance and nothing more. An example of this type of conflict includes poorly designed traffic intersections that don’t reflect the reality of how roads are used.

These types of minor conflicts can be addressed by bringing them to the attention of the public, writing an article, proposing improvements, etc.

Since most people are busy with their private lives and work, it may be the case that few will care to expend time and energy fixing nuisance laws. Many people will choose, by inaction, to live with a foolish law that is merely annoying. And it is unreasonable to expect that all laws will be perfectly reasonable all the time. Those who claim to defend reason should have reasonable expectations.

Second, there are major conflicts between law and reason where an arbitrary law causes significant harm, hardship or lost opportunities to its victims. As the harm in this case is greater, so too must be the effort to remove the harm. Major conflicts between law and reason must be exposed to the public in every possible way. The law itself should be prosecuted and convicted of wrongdoing by those who seek to defend reason and civilized values.

An example of a major conflict between law and reason includes poorly designed zoning and business signage rules that harm, hinder and add costs to business. Old zoning laws written decades ago may cause enormous economic damage and lost opportunity. The past can destroy or diminish the present.

Perhaps the greatest obstacle to fixing medium-scale conflicts between law and reason is inertia and adaptation to adversity. The status quo wields the dead weight of the past against present attempts to achieve reform. Many people hate to think anew just as they fear change merely because it is change. As the proverb says, frogs will stay inside a pot of water despite the fact that it is starting to boil.

The third and last scale of conflict between law and reason is the ultimate extreme where the frogs inside a near-boiling pot of water decide to jump out at last. At this scale, the conflict between what law requires and what reason requires is so enormous, so obvious, and so harmful that most people will revolt against the law and demand its replacement by reason. Here, at this scale, Revolutions begin, as noted in the second paragraph of our own Declaration of Independence:

That whenever any Form of Government becomes destructive…it is the Right of the People to alter or to abolish it, and to institute new government…as to them shall seem most likely to effect their Safety and Happiness. Prudence, indeed, will dictate that Governments long established should not be changed for light and transient causes…

For all levels of conflict between law and reason, the burden of proof that a law is unreasonable should be on the complainer. This is only fair. Those who complain against unreasonable laws will acquire greater credibility if they do more than just complain, but go further and offer specific and realistic solutions that resolve the conflict between a particular law and reason.

Another complication is that sometimes a law will be a mere nuisance for many and a matter of life or death for a few. Our system of individual rights must protect everyone from such extreme cases.

Finally, it must be noted that there are some people who will stubbornly insist that law prevail over reason. (Inspector Javert from Victor Hugo’s Les Miserables comes to mind.)

Those who believe law must prevail over reason should prove it. Prove you believe law (merely because it is law) should prevail over reason by taking an important portion of your life, like getting paid for the work you do, and subjecting it to a completely arbitrary decision-making mechanism, such as a coin flip.

If a coin flip results in a heads-up, you get paid for that week. Alternatively, if the coin flip comes up tails, sorry, you’re out of luck and don’t get paid. Better luck next time. How would you like to live under such an arbitrary law? No sensible person would want to.

Those who dare to assert that law must prevail over reason should carefully consider the contradictions of this belief. Such individuals stand in a false position and are likely to be the first, but not the only, victims of their own contradictions.

Q.E.D.

The Psychology of Abuse, Misconduct and Failure

Why do people fail in their work? There are three major reasons:

Incompetence

People can’t work effectively if they are not trained and educated appropriately. A blunt tool will work poorly, but might still get something done. A broken tool won’t work at all, but still serves as a message to the user that if it is fixed then work can proceed. No tool at all means no ability to accomplish anything or even to understand what means are needed to accomplish anything. 

Many companies, institutions and municipalities may delude themselves that they can save money by cutting on competence. As I’ve argued elsewhere (“Competence: The Crucial Cost that Can’t be Cut”) this is impossible to do and foolish to try.

Because of a lack of training and knowledge a worker can be doomed to failure before he or she shows up for the first day of work.

Recreational Sadism

Give the wrong person a badge and some power over his or her fellow human beings and you may produce a monster. Secret (undetected) sadists derive enormous emotional satisfaction from imposing harm, hardship and adversity on their victims. Secret sadists are naturally attracted to occupations where they can acquire power.

The psychology of a sadist is brutally simple. These people will compensate for other failings in their personal lives by saying to themselves: ‘I’m a powerful, valuable person because I can hurt other people, and destroy their dreams and ambitions.’ (Sadistic Personality Disorder was specifically discussed in a prior version of the Diagnostic and Statistical Manual of Mental Disorders, DSM-III-R, an authoritative resource for mental health professionals and psychiatrists. The current year 2015 DSM–V treats this syndrome as a subclinical psychopathy.)

It is imperative that companies and organizations take steps to avoid hiring inappropriate individuals for positions of power. One effective screening tool is the Hare Psychopathy Checklist. Other screening tools including conducting extensive background checks and contacting references for a candidate seeking a position of power.

They Just Don’t Care

Indifference guarantees failure. Employees will be indifferent to their work for many reasons, which may include ineffective compensation and incentive pay practices, poor management and oversight by the employer, and poor hiring practices.

Lackadaisical employees will fail in their work because:

1. They don’t work;
   
   
   
2. Management doesn’t notice they are not working; and
   
   
   
3. Customers, clients or taxpayers don’t bring failure to the attention of management. 

If everyone was perfectly indifferent to their work then the whole system will fail. The reality for many companies and institutions is that the maximum level of indifferent, uncaring employees is reached because other caring employees compensate for, absorb, and counter-act the failures produced by indifferent personnel. Thus, those who take their work seriously may be doing at least two jobs: their own plus the job that is not done by an indifferent employee. I’ve been in this position and know exactly what it feels like.

(3) HOW CAN WE FIX ABUSIVE CODE ENFORCEMENT?

Reform

As discussed previously, all complex, rule-based systems have an innate tendency to accumulate debris, arbitrary rules, clutter and ambiguity. Systems decay and lose relevance and effectiveness by the passage of time, changing circumstances, and innovation.

The first task of government is to respond to recent events and challenges by enacting new rules. For example in 2007 Maine passed the Uniform Building and Energy Code, an attempt to bring the state’s code enforcement into the 21st century and promote greater consistency and uniformity of code enforcement rules.

The second task of government, just as important as the first, is reform: Search for, find, and delete arbitrary rules and replace them with good judgment and good thinking. Protect the relevancy and currency of law.

In any contest between law and reason a civilized society will make sure reason ultimately prevails.

A city must speak with one voice and act with one will. I think it’s a great idea for the economic development department of a city to communicate and collaborate with the code enforcement department. In this way, what the right hand attempts to build up and create will not be pulled down and destroyed by the left hand.

Government Has a Duty to Police Itself

Maine’s code enforcement system relies heavily on private litigation to challenge code enforcement abuse and misconduct. This fact places a high burden on business and property owners who are victimized by code enforcement overreach. Private legal action is expensive and risky and attorneys typically require payment of a substantial retainer before they will take on a case. 

Victims of code enforcement abuse and misconduct should consider reporting the incident to their local District Attorney. A variety of state laws exist limiting the power of municipal officials. When code enforcement personnel cross the line and break the law they should be held personally responsible, the same as anyone else. Government has a duty to prosecute unscrupulous individuals who abuse their power in order to indulge in private vendettas at great public cost.

It should be mentioned that code enforcement personnel have “statutory immunity” from personal liability, but only if they act “properly” and “in good faith.”

Towns are NOT above the law, as clearly stated in the 2009 Maine Municipal Code Enforcement Officer Training and Certification Information Guide (p. 40):

“…the law does not protect a municipality when it knowingly makes decisions or acts improperly regarding administration and enforcement of ordinances and state regulations.”

Ask Eighth-Graders for Help

When it comes to reforming code enforcement, there is a resource that is pure at heart, uncorrupted by dirty politics, and actually willing to think and take their work seriously: Eighth-graders. By eighth grade many students begin taking classes in civics and learning about government.

I am highly confident eighth graders could come up with some very helpful proposals for reforming code enforcement and zoning practices here in Maine. It’s because things are so bad that improvement is so easy. Students should be asked to solve crucial questions such as the following:

-How should zoning districts be determined?

-What is the best type of sign ordinance?

-How restrictive should code enforcement be when property owners seek to expand or modify their buildings?

-Should small family businesses be required to submit a full-blown site plan when the manner in which a property is being used remains substantially the same?

Of course these students will learn about the ‘taking clause’ included in the Fifth

Amendment to our Constitution:

“...nor shall private property be taken for public use, without just compensation.”

After reviewing the way code enforcement and zoning is practiced in Maine, some students may feel the work of mindless mediocrities is painfully self-evident, and will demand, require and expect better from a government that is charged with serving them and their parents.

If the powers-that-be are humiliated at receiving good advice from eighth graders, so be it. They deserve it, and may yet learn from the example of children what they are required to achieve as adults charged with governance. Every eighth grade student knows he or she must get at least a C in order to pass a class. For serious matters effecting the life, well-being, and property of citizens we should require government to get at least a B and preferably an A+.

Private Cooperative Action

I am considering forming a non-profit statewide organization to be called “CodeWatch” that will serve as a clearinghouse of publicly reported information on code enforcement abuse and misconduct. This organization will need trained personnel including former code enforcement officers, public safety workers and other experienced individuals. Our goal is to sort out mere idle complaints from blatant and extreme cases that would be referred to appropriate state and federal officials for further action.

Flagrant cases of code enforcement abuse and misconduct would be publicized to the wider community. Sunlight and transparency sterilize. In the court of conscience judgment may be based on confidential, insider knowledge and direct personal insight. Sometimes it is the case that a very few know far better than what can be proven to very many. CPA’s, like lawyers, can connect dots most people don’t even know exist. What is void in a court of law as mere ‘hearsay’ may yet be persuasive in the court of public opinion.

Code enforcement should be a technical profession, not a means of indulging in dirty politics.

Our silence and inaction give illegitimate power to government officials. When it comes to code enforcement you, as a business or property owner, may be dealing with a punk with a badge and an attitude who thinks he or she is God’s gift to your zip code.

When I began my career as an accountant I worked over four years for the largest CPA firm in the world at that time (they had over 160,000 employees.) We were paid every week. At the top of every paycheck, printed in BIG, BOLD LETTERS was the following phrase: “BROUGHT TO YOU BY OUR CLIENTS.” This firm wanted to drill home the point that the money didn’t fall from the sky for free. 

I highly recommend something similar for all public-sector workers. At the top of every paycheck for public sector workers, whether federal, state or local, I believe the following phrase should be printed in BIG, BOLD LETTERS:

BROUGHT TO YOU BY THE TAXPAYERS YOU ARE SWORN TO SERVE

Code enforcement can be evaluated along a spectrum where there are two extremes. At one extreme are cities (including places in Asia and South America) where there is no code enforcement of any kind. This results in a free-for-all where cities lack organization and basic health and safety rules. No sensible person would want this. The answer here is to create reasonable rules and enforce them.

At the opposite extreme of the spectrum of code enforcement is the case where local government (Gestapo-style) aggressively micromanages every aspect of what property owners and businesses can and can’t do. No sensible person would want this either. The answer in this case is to reform the law and report cases of blatant abuse and misconduct.

When it comes to arbitrary, hurtful action by government I’ve had it. I’m sick and tired of hearing about it from my clients, seeing and experiencing it personally, and paying for it with the taxes I incur as a citizen.

I don’t want to live in North Korea or Communist China, where all-powerful central governments dictate and control every aspect of personal life. I do want to live in a free country of limited government where, if I pay my taxes and obey the law the government leaves me alone, and doesn’t hurt, harm, threaten or hinder my business, which is the means by which I put food on the table through honest work. I don’t think this is too much to ask for.

The failure to report an offense is another offense. 

Photo Acknowledgements and Credits: Women Arm Wresling by ©carlodapino | Can Stock Photo Inc. / Mountain Top & Sky by ©olly2 | BigStock.com / Composition & Modifications by Shawn Hill | VASTmicro

LEGAL DISCLAIMER

George Adams
Certified Public Accountant Master of Business Administration
Tel: (207) 989-2700 E-Mail: GeorgeAdams@IntelligenceForRent.com
450 South Main Street: The HQ of IQ
Brewer, Maine 04412-2339

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