608 research outputs found

    Forum: The Challenge to Engage and Collaborate

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    Forum: What Shall We Read?: Getting a Life, The Letters of Paul

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    Migrants: Illegals or God\u27s Ambassadors?

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    The nature of a Small Town Church in Granville, Ohio.

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    Letter was objectionable outburst

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    John Sandblom\u27s letter to the editor was a disgraceful and disillusioning example of how intolerant some people can be

    The Office of the General Counsel of the Air Force

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    TAXATION - COMPENSATING USE TAX - THEORY - BURDEN ON INTERSTATE COMMERCE

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    The California Use Tax Act of 1935 imposes an excise tax on the storage or use of personal property purchased in other states and brought into California. Plaintiff railroad bought materials and supplies in other states and stored them in California before installation on its interstate railroad system, and the tax was assessed on them. Held, the tax is unconstitutional as applied to such property as a direct burden on interstate commerce. Where the property was purchased for the sole purpose of being reserve equipment in an interstate commerce plant it is employed in interstate commerce from the time of its purchase. Southern Pacific Co. v. Corbett, (D. C. Cal. 1937) 20 F. Supp. 940

    THE EFFECT OF POLO DRILL SWIMMING ON FREESTYLE KINEMATICS: A PILOT STUDY

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    The purpose of this pilot study was to compare temporal performance variables and kinematic parameters during the entry and catch phase of freestyle and Polo drill swimming. Five well-trained freestyle swimmers performed 400 m of Polo drill and freestyle through a 8.91 m3 calibrated space recorded by eight synchronised cameras. Differences were assessed by a paired t-test and effect size (d) calculations for each variable. Significant differences occurred with respect to stroke length, stroke rate, stroke duration, entry and catch duration, hip velocity and vertical displacement and trunk inclination. The finger displacement and velocity, elbow angle and shoulder displacement were not significantly different through the entry and catch phase of the stroke. This work identified that while notable differences exist between freestyle and Polo drill swimming, there is an indication that some key parameters may be similar

    TAXATION - INCOME TAX - SURTAX ON INCOME OF CORPORATION WHERE PROFITS ARE ACCUMULATED TO AVOID SURTAX ON INCOME OF ITS SHAREHOLDERS - CONSTRUCTION

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    Section 104 of the Revenue Act of 1928 imposed a surtax on the net income of any corporation formed or availed of for the purpose of preventing the imposition of the surtax on its shareholders through the medium of permitting its gains and profits to accumulate instead of being divided and distributed, and provided that the fact that the gains or profits are permitted to accumulate beyond the reasonable needs of the business shall be prima facie evidence of a purpose to escape the surtax. Defendant corporation was formed in 1911 with 200,000capitalstockallownedbyKohl.In1931thenetprofitsofthecorporationweremorethan200,000 capital stock all owned by Kohl. In 1931 the net profits of the corporation were more than 682,000 and it had a surplus of nearly 8,000,000.Itsexcessofcashonhandoveraccountspayablewas8,000,000. Its excess of cash on hand over accounts payable was 1,136,820. It had declared no dividends since 1919 when the high personal surtaxes went into effect. If it had declared dividends of profits in each of those years the additional surtax paid by Kohl would have been 1,240,852andifithaddeclaredallofits1931profitsindividendsKohl2˘7sadditionalsurtaxfortheyearwouldhavebeenmorethan1,240,852 and if it had declared all of its 1931 profits in dividends Kohl\u27s additional surtax for the year would have been more than 115,000. During the past seven years Kohl had borrowed $610,000 from the corporation. Held, the corporation was liable for the surtax imposed by section 104. The tax is constitutional, and is applicable to a legitimate business corporation availed of for the forbidden purpose. There was ample evidence that the surplus accumulated was in excess of the reasonable needs of the business; and, even without the aid of the presumption, there was sufficient evidence to show that the corporation was availed of to withhold dividends to defeat the surtax on the stockholder. Helvering v. National Grocery Co., 304 U. S. 282, 58 S. Ct. 932 (1938), rehearing denied 59 S. Ct. 56
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