United States Trust Co. v. I.R.S.

During the course of its administration, an estate may receive income that is subject to federal income tax. When, and if, an estate receives such income the executor is faced with the task of filing the estate\u27s income tax return along with a number of related considerations. One of the more important considerations is the allocation of the burden of such tax between the beneficiaries of the estate and the estate itself. Subchapter J of the Internal Revenue Code provides the mechanism to allocate that burden between the beneficiaries and the estate. Generally, Subchapter J attempts to allocate the tax liability according to the amount of income the estate retains and the amount of income which it distributes to beneficiaries. It does so, generally, by providing the estate an income tax deduction for amounts of income distributed to beneficiaries. United States Trust Co. v. I.R.S. involved this precise issue. The estate sought to deduct income it had distributed to a charitable beneficiary so that it would not be subject to any income tax liability with respect to this income. The government challenged the validity of this deduction. The government contended that the tax liability relating to such income was totally eliminated, rather than being allocated, because the charitable beneficiary was exempt from federal income tax. In holding for the estate, the court rested its decision on a literal reading of the statutory framework of Subchapter J

LSST: from Science Drivers to Reference Design and Anticipated Data Products

(Abridged) We describe here the most ambitious survey currently planned in the optical, the Large Synoptic Survey Telescope (LSST). A vast array of science will be enabled by a single wide-deep-fast sky survey, and LSST will have unique survey capability in the faint time domain. The LSST design is driven by four main science themes: probing dark energy and dark matter, taking an inventory of the Solar System, exploring the transient optical sky, and mapping the Milky Way. LSST will be a wide-field ground-based system sited at Cerro Pach\'{o}n in northern Chile. The telescope will have an 8.4 m (6.5 m effective) primary mirror, a 9.6 deg$^2$ field of view, and a 3.2 Gigapixel camera. The standard observing sequence will consist of pairs of 15-second exposures in a given field, with two such visits in each pointing in a given night. With these repeats, the LSST system is capable of imaging about 10,000 square degrees of sky in a single filter in three nights. The typical 5$\sigma$ point-source depth in a single visit in $r$ will be $\sim 24.5$ (AB). The project is in the construction phase and will begin regular survey operations by 2022. The survey area will be contained within 30,000 deg$^2$ with $\delta<+34.5^\circ$, and will be imaged multiple times in six bands, $ugrizy$, covering the wavelength range 320--1050 nm. About 90\% of the observing time will be devoted to a deep-wide-fast survey mode which will uniformly observe a 18,000 deg$^2$ region about 800 times (summed over all six bands) during the anticipated 10 years of operations, and yield a coadded map to $r\sim27.5$. The remaining 10\% of the observing time will be allocated to projects such as a Very Deep and Fast time domain survey. The goal is to make LSST data products, including a relational database of about 32 trillion observations of 40 billion objects, available to the public and scientists around the world.Comment: 57 pages, 32 color figures, version with high-resolution figures available from https://www.lsst.org/overvie

Actions:The return of urban guerrillas

In this opening chapter of the first part of this book, I analyse the current threat of terrorism as regards the safety and security of our cities and our open societies. The themes of vulnerability of these open societies, and the criticality of certain parts of urban infrastructures the existence and smooth functioning of which we tend to take for granted form the backdrop to the discussion of the growing threat to our cities, moving from assassination-style attacks of, for example, the German Red Army Faction and the bombing attacks of the IRA against the City of London to mass-casualty attacks targeting our Western way of life and our ‘sinful’ cities as such by actors associated with Al Qaeda and ISIS/Daesh on the one hand and attacks by way of weaponizing ‘mundane objects’ such as cars, vans, trucks or simple knifes for that matter. My main argument here is that our growing urban sprawls now provide terrorists with an ‘urban jungle’ Marighella could only dream of when he wrote his Minimanual of the Urban Guerrilla in the late 1960s.</p

Downregulation of IRF8 in alveolar macrophages by G-CSF promotes metastatic tumor progression

Summary: Tissue-resident macrophages (TRMs) are abundant immune cells within pre-metastatic sites, yet their functional contributions to metastasis remain incompletely understood. Here, we show that alveolar macrophages (AMs), the main TRMs of the lung, are susceptible to downregulation of the immune stimulatory transcription factor IRF8, impairing anti-metastatic activity in models of metastatic breast cancer. G-CSF is a key tumor-associated factor (TAF) that acts upon AMs to reduce IRF8 levels and facilitate metastasis. Translational relevance of IRF8 downregulation was observed among macrophage precursors in breast cancer and a CD68hiIRF8loG-CSFhi gene signature suggests poorer prognosis in triple-negative breast cancer (TNBC), a G-CSF-expressing subtype. Our data highlight the underappreciated, pro-metastatic roles of AMs in response to G-CSF and identify the contribution of IRF8-deficient AMs to metastatic burden. AMs are an attractive target of local neoadjuvant G-CSF blockade to recover anti-metastatic activity