Microsoft Office Real-Time Productivity Features Exclusively for iPhone and iPad

Microsoft recently launched a real-time productivity feature for iPhone and iPad users. The feature will improve the efficiency of your work on Microsoft Office. The September feature has updated Office applications like Word, Excel and PowerPoint. So, let’s read about the feature in detail:

As the name describes, this real-time feature will let you see where others are working. Not just this, you can also make changes to a particular document, spreadsheet or more, and others can see these changes instantly. This basically focus on team work from remote places as you can see in real-time what your colleagues are typing in MS Word documents.

However, if you don’t have time to regularly check the changes that the other users are making in the Word document, then simply set an alert for it. To enable this, Open the menu and enable Office notifications, which will work for Word documents, Excel spreadsheets and PowerPoint presentations. For iPad users, a new Outlook feature has been rolled out. This feature would help them connect with what’s happening at the Office.

So, you can now check out messages full screen and shift to calendar views in no time. The new and better date picker will help you schedule your tasks and meets to make it easy for you tackle with the upcoming challenges. By using this feature, you can access your incoming emails faster than ever. In the same way, sending emails would also be a task of seconds.

The new real-time productivity feature gives you the freedom to share just one slide instead of sharing the whole presentation. So, if you want to send someone a rough idea of the layout of the entire presentation via a slide, you can make it possible now! Get it now and enjoy amazing features. If you facing any issues in updating or finding it, contact with Microsoft Customer Support team.

Fourth Circuit Rules on New Evidence Submitted to Appeals Council

In a recently published opinion, the U. S. Court of Appeals for the Fourth Circuit resolved a conflict within the Circuit over the summary denial of requests for review when new evidence is submitted to the Appeals Council. Meyer v. Astrue, 662 F.3d 700 (4th Cir. 2011) The court rejected arguments that the Appeals Council has a duty to articulate reasons for denying a request for review, but went on to reverse the Commissioner and remand the case for administrative findings of fact regarding new and material opinion evidence submitted to the Appeals Council.

Meyer suffered severe spinal injuries when he fell 25 feet out of a stand while hunting. His neurosurgeon and pain management doctors declined to provide medical opinions in support of the disability claim, forcing Meyer to obtain an independent medical examination (IME) to prove his case. The ALJ rejected the IME opinion and denied the claim, noting that none of Meyer’s treating physicians had expressed an opinion concerning work-related restrictions.

On request for Appeals Council review, Meyer was advised to make another attempt at getting the treating neurosurgeon to support his claim. This time, the doctor agreed to help and prepared a detailed opinion letter. The Appeals Council admitted the new opinion into the administrative record but summarily denied the request for review.

The Fourth Circuit agreed with the majority of the circuits in holding that neither the Social Security Act nor the regulations requires the Appeals Council to articulate reasons for its decision to deny a request for review, even when new and material evidence is submitted at the Appeals Council level. The court also held that when the Appeals Council denies a request for review, the ALJ decision becomes the final decision of the Commissioner for purposes of the judicial review statute, 42 U.S.C. § 405(g).

The Court also held that lack of administrative analysis of new evidence by the Appeals Council does not render judicial review “impossible”—as long as the record provides an adequate explanation of the Commissioner’s decision. In such cases the Court can either affirm or reverse outright based solely on its review of the administrative record as a whole.

While the Fourth Circuit affirmed the Commissioner’s interpretation of the Act and regulations regarding Appeals Council review, the court reversed and remanded the case on the ground that the court could not determine whether substantial evidence supported the ALJ decision without further findings of fact by the Commissioner regarding the new opinion evidence submitted to the Appeals Council. In so ruling, the Fourth Circuit relied on its prior holding in Wilkins v. Sec’y, Dep’t of Health & Human Servs., 953 F.2d 93 (4th Cir. 1991)(en banc).

The Court outlined a range of options available to reviewing courts when new evidence is submitted to the Appeals Council. At one end of the spectrum the Court cited Smith v. Chater, 99 F.3d 635 (4th Cir. 1996), as an example of an ALJ decision that is supported by substantial evidence and should be affirmed despite the submission of new evidence, because the new evidence is not material. On the other end of the spectrum is Wilkins, which the Court cited as an example of when it is appropriate to reverse an ALJ decision outright, with instructions to award benefits because the new and material evidence submitted to the Appeals Council is not controverted by other evidence in the record. The third option available to reviewing courts, which lies between the two bookends of affirmance and outright reversal, occurs when the court cannot determine whether substantial evidence supports the ALJ denial of benefits because the new evidence is material but there is other competing evidence of record that conflicts with the new evidence.

The Fourth Circuit concluded that Meyer’s new evidence required the middle path of remand for administrative findings of fact. The Court concluded that assessing the probative value of competing evidence is quintessentially the role of the fact-finder, not the courts. In cases in which the Commissioner has not made any findings of fact regarding new and material evidence submitted to the Appeals Council, and there is other evidence of record which conflicts with the new evidence, the court cannot undertake that action in the first instance but must remand the case instead.

The Court also acknowledged that in some cases, additional administrative fact-finding would be helpful for purposes of judicial review, though not required by the regulatory scheme. The Court went on to observe that analysis of new evidence by the Appeals Council or remand by the Appeals Council to the ALJ for such analysis, would be “particularly” helpful when the new evidence constitutes the only medical opinion evidence in the record from a treating physician.

The Meyer case will be disappointing to those looking for a bright line test. The Fourth Circuit firmly held that it is not the role of the courts to weigh evidence. And the court made it clear that it will not reverse outright or remand a case based on new evidence submitted to the Appeals Council unless that evidence is material in the sense that it could have changed the ALJ’s decision. But the court’s determination of materiality requires it to evaluate the administrative record as a whole—and how can this be accomplished unless the court, to some degree, weighs the evidence?

Practice Tips

While the Meyer decision may not simplify federal court appeals in which new evidence is submitted to the Appeals Council, it does provide some valuable lessons for Social Security practitioners.

• First and foremost, Meyer emphasizes the primacy of the treating physician opinion in determining whether a claimant is disabled. If the new evidence submitted at the Appeals Council level is the opinion of a treating physician, the court is more likely to find that the new evidence is material and that reversal or remand is warranted. This is particularly the case when the new evidence constitutes the only opinion evidence in the record from a treating physician.

• The second lesson to be gleaned from Meyer is that attorneys should always strive to obtain and submit new evidence from treating physicians at any level of appeal, including the Appeals Council or federal court. In cases such as Meyer, a treating physician who was reluctant to give a written opinion at the hearing level may be convinced to provide that opinion on appeal when advised that the case was denied because the doctor had declined to help. Attorneys should consider taking cases at the Appeals Council level even though the claimant was previously represented by another attorney or appeared at the hearing pro se. Many of these cases can be won on appeal by submitting a new treating physician’s opinion, particularly when there was no treating physician opinion in the record before the ALJ.

• Last of all, Meyer suggests that when a treating physician refuses to provide an opinion prior to the ALJ hearing, it is important to document that fact in the record. Meyer’s efforts to get opinions from his treating physicians prior to the hearing were addressed in the pre-hearing brief, Meyer’s testimony, and in closing argument at the hearing. These facts were cited by the Fourth Circuit and highlighted the materiality of the new treating physician opinion. While there is no good cause requirement for submission of new evidence at the Appeals Council level, the fact that Meyer had been diligent in seeking a treating physician opinion made the case for a remand far more compelling to the reviewing court.

Robertson H. Wendt Jr., is a board certified attorney who specializes in Social Security disability law in Charleston, SC. Find out more about him at www.robertsonwendt.

How Tax Calculator Can Save Your Time & Money?

Throughout our life, we search for things that can either save our time or our money. This one thought is the reason behind most of the advancements that we see today. One such tool that you can use to not only save your time but also money is the online tax calculator. This masterpiece was created with the objective to simplify the tax liability calculation for people who either don’t have the knowledge or the time to calculate them on their own. So, let’s see how you can use this tool to save your time and money.

How Tax Calculator Can Save Your Time?

Do you know the maximum time you will require to calculate the taxes with online tax calculator? Well, you will be amazed to know that it is just 2 minutes. Yes, you read that right. The time which your Maggie will take to get cooked, you will be ready with your tax calculations. Have a look at the whole procedure for calculations of taxes.

Step 1: Find a good tax calculator and open it in your browser.

Step 2: You will see four bars. In the first bar, enter your age bracket. There will be four options, so select the one that best defines you as different age groups have different taxation rates.

Step 3: In the 2nd bar enter your residential status. Here, you will see three options, which are resident, non resident, and non-ordinary resident. Select the one that best fits your status.

Step 4: In the third bar, you will have to type down your annual income. It is suggested that you input the exact amount, as the taxation rates for each income slab is different.

Step 5: In the fourth bar, you have to specify that if you are liable for any tax deduction. Here, you have to input the amount that you have invested in any tax saving instruments (ELSS, PPF, FD, LIC, etc.,). If you don’t have any, then leave it blank.

Now, as soon as you hit enter, you will be provided with the taxes that you have to pay in that year. The best thing about the online tax planner is that it is updated with the latest taxation trends and the results it provides are super accurate.

How to Save Money with a Tax Calculator?

As we’ve discussed above that this tool has a feature which allows you to calculate the reductions you will get by investing in the tax saving instruments. But, this feature can also be used to find the investment amount to save the most from your tax saving instruments. Let’s see how!

First of all, the most important thing you should know is tax saving instruments especially u/s 80C allows investors to enjoy tax reductions on investments up to Rs. 1.5 lakhs. Now, the tax calculator can help you find the right amount that you will require to get the best benefits from these instruments. Say, you have a salary of Rs. 5.5 lakhs and you want to invest in a tax saving instrument to get benefits. So, in the 4th bracket which is for tax reductions, put different investment values and keep on this process until you reach the desired tax saving amount.

Now that you know how the online tax calculator can help you in saving time as well as money, don’t wait for the last minute and start your investments today. Also, I would suggest you that if you have not invested in any instrument for saving taxes, then go for ELSS funds, as though these not only help you get the optimal 80C benefits, the growth you will experience on your instruments will be exceptional.