Federal Estate and Gift Taxation of Joint Interests: Planning and Policy Perspectives

This Note will first provide a brief background outlining the incidents of joint tenancy which make it an attractive form of co-ownership under state law. This background section also will place joint ownership in the overall perspective of federal estate and gift taxation by pointing out the impossibility of achieving certain basic federal estate planning objectives in an estate composed primarily of jointly held assets. The Note will then analyze the specific provisions of the Internal Revenue Code governing federal estate and gift taxation of joint interests. This analysis will: first, focus on some of the legal problems generated by the present provisions and demonstrate the unnecessary uncertainty and complexity fostered by the current scheme of federal estate and gift taxation of joint interests;second, examine the estate planning alternatives available under the present provisions and assess the consistency of these provisions with the overall system of estate and gift taxation enacted by the Tax Reform Act of 1976; third, point out a solution to the problems of federal estate and gift taxation of joint ownership between non-spouses overlooked in the Tax Reform Act of 1976; and last, demonstrate that the problems of federal estate and gift taxation of inter-spousal joint ownership are inherent in the current scheme of federal estate and gift taxation of married couples and that these problems illustrate the need for comprehensive reform in this area of the estate and gift tax law

Visual responses in the lateral geniculate evoked by Cx36-independent rod pathways

AbstractEmerging evidence indicates rods can communicate with retinal ganglion cells (RGCs) via pathways that do not involve gap-junctions. Here we investigated the significance of such pathways for central visual responses, using mice lacking a key gap junction protein (Cx36−/−) and carrying a mutation that disrupts cone phototransduction (Gnat2cpfl3). Electrophysiological recordings spanning the lateral geniculate revealed rod-mediated ON and OFF visual responses in virtually every cell from all major anatomical sub-compartments of this nucleus. Hence, we demonstrate that one or more classes of RGC receive input from Cx36-independent rod pathways and drive extensive ON and OFF responses across the visual thalamus

The independent effect of living in malaria hotspots on future malaria infection: an observational study from Misungwi, Tanzania.

BACKGROUND: As malaria transmission declines, continued improvements of prevention and control interventions will increasingly rely on accurate knowledge of risk factors and an ability to define high-risk areas and populations at risk for focal targeting of interventions. This paper explores the independent association between living in a hotspot and prospective risk of malaria infection. METHODS: Malaria infection status defined by nPCR and AMA-1 status in year 1 were used to define geographic hotspots using two geospatial statistical methods (SaTScan and Kernel density smoothing). Other malaria risk factors for malaria infection were explored by fitting a multivariable model. RESULTS: This study demonstrated that residing in infection hotspot of malaria transmission is an independent predictor of malaria infection in the future. CONCLUSION: It is likely that targeting such hotspots with better coverage and improved malaria control strategies will result in more cost-efficient uses of resources to move towards malaria elimination

Expression of Integrin-αE by Mucosal Mast Cells in the Intestinal Epithelium and Its Absence in Nematode-Infected Mice Lacking the Transforming Growth Factor-β1-Activating Integrin αvβ6

Peak intestinal mucosal mast cell (MMC) recruitment coincides with expulsion of Trichinella spiralis, at a time when the majority of the MMCs are located within the epithelium in BALB/c mice. Although expression of integrin-α(E)β(7) by MMCs has not been formally demonstrated, it has been proposed as a potential mechanism to account for the predominantly intraepithelial location of MMCs during nematode infection. Co-expression of integrin-α(E)β(7) and the MMC chymase mouse mast cell protease-1, by mouse bone marrow-derived mast cells, is strictly regulated by transforming growth factor (TGF)-β(1). However, TGF-β(1) is secreted as part of a latent complex in vivo and subsequent extracellular modification is required to render it biologically active. We now show, for the first time, that intraepithelial MMCs express integrin-α(E)β(7) in Trichinella-infected BALB/c and S129 mice. In S129 mice that lack the gene for the integrin-β(6) subunit and, as consequence, do not express the epithelial integrin-α(v)β(6), integrin-α(E) expression is virtually abolished and recruitment of MMCs into the intestinal epithelium is dramatically reduced despite significant overall augmentation of the MMC population. Because a major function of integrin-α(v)β(6) is to activate latent TGF-β(1,) these findings strongly support a role for TGF-β(1) in both the recruitment and differentiation of murine MMCs during nematode infection

The host stars of Kepler's habitable exoplanets : superflares, rotation and activity

We embark on a detailed study of the light curves of Kepler's most Earth-like exoplanet host stars using the full length of Kepler data. We derive rotation periods, photometric activity indices, flaring energies, mass-loss rates, gyrochronological ages, X-ray luminosities and consider implications for the planetary magnetospheres and habitability. Furthermore, we present the detection of superflares in the light curve of Kepler-438, the exoplanet with the highest Earth Similarity Index to date. Kepler-438b orbits at a distance of 0.166 au to its host star, and hence may be susceptible to atmospheric stripping. Our sample is taken from the Habitable Exoplanet Catalogue, and consists of the stars Kepler-22, Kepler-61, Kepler-62, Kepler-174, Kepler-186, Kepler-283, Kepler-296, Kepler-298, Kepler-438, Kepler-440, Kepler-442, Kepler-443 and KOI-4427, between them hosting 15 of the most habitable transiting planets known to date from Kepler

Multiwaveband Observations of Quasars with Flat Radio Spectra and Strong Millimeter Emission

We present multiwaveband observations of a well selected sample of 28 quasars and two radio galaxies with flat radio spectra and strong millimeter wave emission (referred to here as FSRQ's). The observations include multifrequency VLBI measurements, X-ray observations with ROSAT and submillimeter observations with the JCMT. Particularly interesting among many findings is a correlation between the X-ray to millimeter spectral index and fraction of flux density contained in the VLBI core. This tendency toward higher X-ray fluxes from sources with stronger jet emission implies that the knots in the jet are the prominent source of X-rays.Comment: 38 pages, 17 figures, 12 tables, accepted for publication in Ap J Suppl, May 199

Arctic marine phytobenthos of northern Baffin Island

This project was supported by SAMS and NFSD core funding (Oceans 2025 WP 4.5 from the UK Natural Environment Research Council), the European Commission (ASSEMBLE, grant agreement no. 227799), and the TOTAL Foundation (Paris; Project “Macroalgal and oomycete benthic diversity in the Canadian Marine Arctic”). This work also received funding from the MASTS pooling initiative (The Marine Alliance for Science and Technology for Scotland) and their support is gratefully acknowledged. MASTS is funded by the Scottish Funding Council (grant reference HR09011) and contributing institutions. We also would like to thank Laura Grenville-Briggs (KTH, Stockholm) for help with bioinformatics analyses as well as Cindy Grant and Philippe Archambault (University of Quebec, Rimouski) for help with preparing the map of the study area (Fig. 1).Peer reviewedPublisher PD

Single transit candidates from K2 : detection and period estimation

Photometric surveys such as Kepler have the precision to identify exoplanet and eclipsing binary candidates from only a single transit. K2, with its 75 d campaign duration, is ideally suited to detect significant numbers of single-eclipsing objects. Here we develop a Bayesian transit-fitting tool (‘Namaste: An Mcmc Analysis of Single Transit Exoplanets’) to extract orbital information from single transit events. We achieve favourable results testing this technique on known Kepler planets, and apply the technique to seven candidates identified from a targeted search of K2 campaigns 1, 2 and 3. We find EPIC203311200 to host an excellent exoplanet candidate with a period, assuming zero eccentricity, of 540+410 −230 d and a radius of 0.51 ± 0.05RJup. We also find six further transit candidates for which more follow-up is required to determine a planetary origin. Such a technique could be used in the future with TESS, PLATO and ground-based photometric surveys such as NGTS, potentially allowing the detection of planets in reach of confirmation by Gaia