Fiduciary Income Taxation and the Holloway Adjustment

A great deal of the complexity of the rules dealing with income taxation of trusts and estates\u27 can be attributed to the imperfect compatibility of two different regimes of law: the federal taxation of income and local rules of trust accounting. Just as the confluence of two rivers may generate turbulence exceeding that of either branch, the meeting of federal tax law and state trust law in Subchapter J of the Internal Revenue Code generates problems that neither discipline would present by itself. In 1972, a New York Surrogate\u27s Court introduced the Holloway adjustment to fiduciary accounting. This equitable adjustment was seen as necessary to restore the balance between the interests of income and principal beneficiaries of certain trusts after that balance had been upset by the effects of Subchapter J, particularly where executors had utilized a popular tax-saving technique known as the trapping distribution. \u27 In these instances, the first element of the federal/local law interaction would be the Subchapter J tax rules that make trapping distributions possible. The second level, the response of local trust law to a tax-induced inequity, is the Holloway adjustment itself. The third level, and the subject of this article, is the federal tax law\u27s treatment of the new relationships created by the Holloway adjustment. At this point, an introduction to trapping distributions and to the Holloway adjustment is necessary

The effect of cadmium on the bovine in vitro oocyte maturation and early embryo development

Common pollutants such as heavy metals and cadmium is among those with high environmental concerns. In vivo studies had shown that cadmium (Cd) causes oocyte degeneration and embryo mortality, and lowers pregnancy rates in mammals. However, there is limited information available about direct effects of Cd on oocyte maturation and/or embryo development. This study was aimed to investigate if Cd has any effect on the oocyte maturation and/or embryo development in vitro. Bovine COCs were collected from the slaughter house and cultured for 24 h in serum-free media only (Controls) or supplemented with 0.2, 2.0 and 20.0 μM CdCl2. At 24 h cumulus cell expansion was assessed in all COCs. COCs were either denuded and stained for determination of nuclear maturation or fertilized for assessment of subsequent embryo development. Cd at the lowest concentration (0.2 μM) did not affect any of the parameters studied. However, at higher concentrations (2.0 and 20.0 μM) it significantly (P < 0.05) reduced the percentage of fully-expanded COCs and significantly (P < 0.05) increased the percentage of partially and/or non-expanded COCs compared to controls and 0.2 μM. Cadmium at higher concentrations (2.0 and 20.0 μM) also significantly (P < 0.01) reduced the percentage of oocytes reaching metaphase II stage compared to controls and 0.2 μM. Post-fertilization cleavage rate in presumptive zygotes and blastocyst development significantly (P < 0.05) reduced 0.2, 2.0 and 20.0 μM CdCl2 compared to the controls (0.0 μM). In conclusion, these results suggest that Cd had direct detrimental effects on the bovine oocyte maturation and its developmental competence

Fiduciary Income Taxation and the Holloway Adjustment

A great deal of the complexity of the rules dealing with income taxation of trusts and estates\u27 can be attributed to the imperfect compatibility of two different regimes of law: the federal taxation of income and local rules of trust accounting. Just as the confluence of two rivers may generate turbulence exceeding that of either branch, the meeting of federal tax law and state trust law in Subchapter J of the Internal Revenue Code generates problems that neither discipline would present by itself. In 1972, a New York Surrogate\u27s Court introduced the Holloway adjustment to fiduciary accounting. This equitable adjustment was seen as necessary to restore the balance between the interests of income and principal beneficiaries of certain trusts after that balance had been upset by the effects of Subchapter J, particularly where executors had utilized a popular tax-saving technique known as the trapping distribution. \u27 In these instances, the first element of the federal/local law interaction would be the Subchapter J tax rules that make trapping distributions possible. The second level, the response of local trust law to a tax-induced inequity, is the Holloway adjustment itself. The third level, and the subject of this article, is the federal tax law\u27s treatment of the new relationships created by the Holloway adjustment. At this point, an introduction to trapping distributions and to the Holloway adjustment is necessary

Privacy Preserving Device-Bound Information

A common abuse scenario is one in which a malicious user repeatedly performs actions that are intended by a developer, vendor, or service provider to be limited. For example, a user may repeatedly take undue advantage of one-time free trials, coupons, or account creation flows. This disclosure describes techniques to verifiably attach data to a particular device in a privacy-preserving manner such that the data can survive a factory reset or compromise of the device. Data is bound to the device in a privacy-preserving manner such that the data cannot be used as a mechanism for identifying a particular device. Developers can bind an abuse bit to a device such that even when the device is used with a fresh user account, it can be determined that abuse has been attempted from the device previously. Counters in device-bound data enable setting thresholds to detect abuse of services or products

Systemic Lupus Erythematosus for the PCP

Objectives Define Systemic Lupus Erythematosus (SLE) and understand it’s clinical manifestations and diagnosis Become familiar with the treatment of SLE Discuss SLE through the life stages including pregnancy counseling and contraceptive use Discuss preventative measures for SLE patients Develop a better understanding of the role of PCPs in the care of SLE patient

Head and Neck Injuries for the PCP

Objectives: Define and recognize common symptoms and treatments of head and neck injuries Become more familiar and comfortable with the history and physical exam techniques of common head and neck injuries Know when to seek a higher level of care for certain common head and neck injurie

Training and Endothelial Function In Upper and Lower Limbs

Cardiovascular disease (CVD) begins with damage to the endothelium, the inner lining of the blood vessels. Endothelial damage occurs as early as childhood and is associated with risk factors such as obesity, hypertension, diabetes, smoking, and dyslipidemia. Previous research has documented that exercise enhances endothelial function in individuals of all ages, but there is no consensus in the literature as to whether this improvement is seen systemically or is localized to the exercised limb. It is well known that endothelial function is not homogenous throughout the body, due to differences in limb blood pressure when standing, which can be as high as 65 mmHg. The purpose of this study was to evaluate endothelial function of the brachial and popliteal arteries of trained and sedentary men via flow-mediated dilation (FMD). FMD is assessed by measuring changes in arterial diameter in the reperfusion period following a 5-minute period of ischemia. We hypothesized that 1) trained men would have greater endothelial function in both the brachial and popliteal arteries in comparison to sedentary counterparts 2) the brachial artery would have better endothelial function than the popliteal artery only in sedentary men. Brachial and popliteal endothelial function will be similar in trained men due to an exercise training improvement in endothelial function of the leg in trained individuals.   Baseline diameter (cm) and blood flow (ml/min) were measured in the brachial and popliteal arteries of 7 lower-body aerobically trained (T) and 7 sedentary (S) young, healthy men. A blood pressure cuff was inflated to occlude the artery for 5 minutes. Upon releasing the cuff, diameter and blood flow were measured intermittently for 5 minutes via Doppler Ultrasound to evaluate the vessel's reactive hyperemic response. FMD was calculated relatively, as a percent change from pre-occlusion, and absolutely, as a cm change from pre-occlusion. The data were analyzed utilizing a 2X2 ANOVA and linear regression.    Trained men exhibited enhanced endothelial function in comparison to sedentary counterparts when FMD was expressed as a percent change (T brachial=15.12 ± 8.44%; S brachial =8.71 ± 2.57%; T popliteal= 8.35 ± 5.03%; S popliteal 5.24 ± 2.57%; p= 0.029) and as an absolute change (T brachial= 0.06 ± 0.03cm; S brachial 0.04 ± 0.01cm; T popliteal=0.05 ± 0.29cm; S popliteal 0.03 ± 0.02cm; p=0.013). In both groups, the brachial artery had better endothelial function than the popliteal artery (p=0.019).    In accordance with the hypothesis, endothelial function was enhanced in trained subjects compared to sedentary controls. However, contrary to our prediction, greater endothelial function was expressed in the brachial than popliteal arteries of both groups. It was concluded that aerobically trained subjects have an improved endothelial function as compared to sedentary subjects in the lower and upper body.  M.S

Rectal Carcinoma Metastasis to the Thyroid Gland - the Role of Radiotherapy: A Case Report

Introduction: To date,  a very rare occurrence of thyroid metastases from rectal cancer is described  in the literature. Although there are no treatment standards for this condition, surgery still has a major role in the treatment of these patients. However, radiotherapy has a controversial role and its significance is rather palliative.Case Presentation: We presented a male patient with metastatic rectal carcinoma to the thyroid gland who has been treated with surgery and palliative radiotherapy in our institution.Conclusion: Although thyroid metastases from rectal cancer are rare, we recommend to think on their potential occurrence what could enable early diagnosis and more successful treatment

Improving Practice Accessibility Through MyChart Utilization

Aims for Improvement Increase patient portal MyChart activation for a cohort of approximately 2,000 patients at JFMA by 1% from February to April 2021. Demonstrate evidence of utilization including appointment scheduling, results review, and communication with providers through MyChart after activation