Reconciling Ripley and Joye: A Fact-Sensitive Analysis of Petition-Year and Pre-Petition-Year Income Tax Claims in Chapter 13 Bankruptcies

Parties to a chapter 13 bankruptcy often contest the status and dischargeability of income tax claims, especially when proofs of claim for these taxes are filed late. Prepetition claims that are filed late may be discharged once the debtor successfully completes a chapter 13 repayment plan. Taxing authorities, however, often allege that these liabilities represent nondischargeable postpetition claims that have become payable after the bankruptcy petition was filed. Courts have resolved this issue in conflicting ways: while some have found that taxes become payable at the end of the taxable year, most have ruled that the tax return\u27s due date was decisive. This Note observes, however, that this conflict appears rooted in a difference of fact. Courts favoring a tax-return rule have been addressing tax claims in the year the bankruptcy was filed. By contrast, courts that apply a taxable-yea r rule have been discussing tax claims for the year immediately preceding the bankruptcy filing. Finding this distinction significant, this Note presents an outline for analyzing income tax liability in chapter 13 cases and concludes that both the type of tax claim faced by each court and the petition-filing timeline are as significant to the courts\u27 analyses as their respective interpretations of the phrase become payable. Applying this framework, this Note illustrates that the taxable- year rule better establishes the critical date upon which taxes should become payable to a taxing authority

Enzyme Specific Stable Isotope Fractionation in Bacterial Dissimilatory Nitrate Reduction

The global nitrogen cycle is largely powered by microorganisms. While mediating these processes, microorganisms leave behind stable isotopic signatures that can be used to identify and trace processes in the nitrogen cycle. However, significant variability has been observed for the stable isotope effects (15&epsilon;) associated with denitrification, the process that returns bioavailable nitrogen (nitrate) from ecosystems to the atmosphere. The first step of denitrification, dissimilatory nitrate reduction to nitrite, is catalyzed by the NapA and/ or NarG enzyme. As microorganisms use nitrate respiration as a source of energy for growth, the key to understanding the variability of isotope effects associated with denitrification lies within the interaction between microbial physiology and the NapA and NarG enzymes. In my dissertation I used a combination of stable isotope geochemistry, microbiology, and molecular genetics to measure the specific isotope effects of both NapA and NarG. Specifically, in the second chapter of my dissertation, I showed that 18&epsilon;/15&epsilon; proportionalities are largely controlled by nitrate reduction with either NarG (18&epsilon;/15&epsilon; value of ~1) or NapA (18&epsilon;/15&epsilon; value of ~0.5) and that the regulation of these enzymes is an important component to ecosystem level trends of 18&epsilon;/15&epsilon; values. In the third chapter, I used chemostat experiments to investigate how microbial growth rates impact the magnitude of 15&epsilon; in NapA based nitrate reduction and observed a range of 19.1 &ndash; 25.1&permil; in 15&epsilon; across growth rates. Using proteomic analyses I also found that the enzyme specific rates of nitrate reduction rather than cell specific rates are key for predicting 15&epsilon; overall. The proteomic data from these chemostat experiments also indicated the simultaneous presence of dissimilatory nitrate reduction to ammonium (DNRA) and denitrifying proteins. Thus, in the fourth chapter of my dissertation I examined the proteomic data closer to determine the possibility of these pathways coexisting. In the final chapter of my dissertation, I assessed the robustness of enzymatically produced stable isotopic signatures by developing a strain of Pseudomonas aeruginosa with a mutated NarG enzyme and by culturing bacteria outside of the Proteobacteria phylum. Though no change to 18&epsilon;/15&epsilon; values occurred in these strains suggesting that the 18&epsilon;/15&epsilon; signature itself is robust, a 6&permil; increase in 15&epsilon; occurred in the mutant strain suggesting that stable isotopic signatures may be sensitive to small mutations through time. By characterizing the isotopic variability associated with nitrate reduction, the findings from this research stand to improve our ability to trace denitrification in natural ecosystems, and therefore, enhance our overall understanding of global nitrogen cycling.</p

Inferior oblique muscle thickness in Asians

The purpose of this study was to examine the inferior oblique muscle (IOM) thickness in Asians by the quasi-sagittal plane of the orbits. Specimens were examined from 23 orbits of 18 Asians (9 orbits in males, 14 in females), aged 63 to 97 years at death. All specimens were fixed in 10% buffered formalin before use. The orbital contents were incised parallel to the optic nerve, after which the lengths of both short and long axes of the IOM were measured and the ratio of short to long axes was calculated. The mean lengths of each short or long axis of the IOM were 2.27 ± 0.49 mm and 7.23 ± 0.97 mm, respectively. The average ratio was 0.32 ± 0.07. There were no significant differences in laterality or gender. This study determined the normal IOM thickness in Asian cadavers, the outcome of which could be useful for detection of IOM involvement in Graves’ orbitopathy

Course of the vertical portion of the lower lacrimal canaliculus

The nomenclature of each part of the lacrimal canaliculus, for example the vertical portion, does not always reflect the true course. Since we have sometimes observed findings suggesting the so called vertical portion of the lower lacrimal canaliculus inclined laterally, we re-examined the course of the vertical portion. Twenty-eight postmortem lower eyelids in 16 Japanese were examined and divided into 2 groups. The first group was 14 lower eyelids of 7 cadavers. Eyelids were incised sagittally from the lower lacrimal punctum. The second group was 14 lower eyelids of 9 cadavers; these were incised from the lower lacrimal punctum with 5 degrees lateral inclination to the sagittal plane. In the first group, 10 canaliculi of 7 cadavers were interrupted at the halfway point of the vertical portion. Four canaliculi of 4 cadavers included the whole length of the vertical portion. In the second group, all specimens included the whole length of the vertical portion. Most vertical portions of the lower lacrimal canaliculus demonstrated a laterally inclined course of approximately 5 degrees, although some took a completely vertical course

Glutathione S-transferase Pi mediates proliferation of androgen-independent prostate cancer cells

Prostate cancers generally acquire an androgen-independent growth capacity with progression, resulting in resistance to antiandrogen therapy. Therefore, identification of the genes regulated through this process may be important for understanding the mechanisms of prostate carcinogenesis. We here utilized androgen-dependent/independent transplantable tumors, newly established with the ‘transgenic rat adenocarcinoma in prostate’ (TRAP) model, to analyze their gene expression using microarrays. Among the overexpressed genes in androgen-independent prostate cancers compared with the androgen-dependent tumors, glutathione S-transferase pi (GST-pi) was included. In line with this, human prostate cancer cell lines PC3 and DU145 (androgen independent) had higher expression of GST-pi compared with LNCaP (androgen dependent) as determined by semiquantitative reverse transcription–polymerase chain reaction analysis. To investigate the roles of GST-pi expression in androgen-independent human prostate cancers, GST-pi was knocked down by a small interfering RNA (siRNA), resulting in significant decrease of the proliferation rate in the androgen-independent PC3 cell line. In vivo, administration of GST-pi siRNA–atelocollagen complex decreased GST-pi protein expression, resulting in enhanced numbers of TdT mediated dUTP-biotin nick-end labering (TUNEL)-positive apoptotic cells. These findings suggest that GST-pi might play important roles in proliferation of androgen-independent human prostate cancer cells

Study on moisture loss and drying shrinkage behaviour of mortar with mineral admixture based on pore structure

The moisture loss and drying shrinkage behavior of mortar with mineral admixture such as blast-furnace slag and fly ash are investigated focusing on the microstructure affected by curing temperature. The curing at high temperature greatly accelerates the hydration reaction of the mortar with mineral admixture to make pore structure denser and leads to smaller moisture loss than that of mortar without mineral admixture. The moisture loss is almost proportional to the accumulated volume of pores whose radii are larger than the radius at the liquid/vapour interface based on the Kelvin equation and BET theory of absorbed water. When the shrinkage is assumed to be induced only by the capillary tension, the estimated shrinkage shows different tendency from experimental one. It suggests that the other shrinkage driving forces that have been believed to be dominant under severe drying conditions should be taken into account even under normal drying condition (RH=60% at 20 degree)

Development and first evaluation of an attractant impregnated adhesive tape against blood-sucking flies

Stable flies are one of the most important arthropod pests of livestock that reduce cattle weight gain and milk production leading to annual economic losses in excess of $2 billion to the US cattle industry. The host-seeking behavior is primarily mediated by associated odors from stable fly larval development environments and host animals. The present paper reports the development and evaluation of attractant-impregnated adhesive tapes to reduce stable fly attacks on cattle. Laboratory bioassays showed that only m-cresol impregnated adhesive tapes caught significantly more stable flies (16 ± 1) than the control tape without attractant added (7 ± 1), with a 77% fly recapture rate. Attractantimpregnated adhesive tapes deployed in cattle feedlots showed significant impacts in reducing fly population, with a total of one million stable flies captured over a period of three weeks (mean catches from 57 596 to 102 088 stable flies per trap per week). It further relieved cattle stress with a significant reduction of biting fly avoidance behavior, (6 ± 0.4 cows observed with tail wagging in control vs. 3 ± 0.4 from the trap-deployed). The efficacy of the developed tapes lasted up to 1-week longevity, although 70% of mcresol was released starting from the second day. The m-cresol impregnated adhesive tape provided an 80% reduction in cattle stress due to stable fly attack. This is the first report of a technology developed by integrating an attractant compound into an adhesive material on a plastic film with demonstrated effectiveness in trapping biting flies that attack livestock animals