Family Partnership v. Corporation--Income Tax Aspects

At the outset, it must be emphasized that a decision as to the more desirable mode of doing business should never be based solely upon tax considerations. In every instance, the following legal and practical advantages of transacting business as a corporation must always be borne in mind: (1) Limited Liability. The liability of a stockholder for the debts of the corporation is limited to his investment in its stock, while all of the property bf a general partner is subject to the claims of the firm\u27s creditors, if its assets are insufficient to satisfy such claims in full. (2) Continuity of Existence. A corporation may have perpetual existence, since changes in the ownership in its shares, whether resulting from the death of a stockholder or otherwise, have no effect upon the continuance of the corporation. Ordinarily the death or withdrawal of a partner dissolves the partnership but a partnership agreement may provide that the firm shall be continued by the surviving partners.(3) Ready Transferability of Shares. The disposal of the interest of a stockholder in a corporation is a very simple matter, since it merely requires the transfer of his stock to another person, but the sale of a partnership interest usually involves an accounting to determine the value of the retiring partner\u27s share. These points are, of course,\u27elementary, but perhaps it may be for that very reason that there is a recent tendency in some quarters to minimize them

SeaWiFS calibration and validation plan, volume 3

The Sea-viewing Wide Field-of-view Sensor (SeaWiFS) will be the first ocean-color satellite since the Nimbus-7 Coastal Zone Color Scanner (CZCS), which ceased operation in 1986. Unlike the CZCS, which was designed as a proof-of-concept experiment, SeaWiFS will provide routine global coverage every 2 days and is designed to provide estimates of photosynthetic concentrations of sufficient accuracy for use in quantitative studies of the ocean's primary productivity and biogeochemistry. A review of the CZCS mission is included that describes that data set's limitations and provides justification for a comprehensive SeaWiFS calibration and validation program. To accomplish the SeaWiFS scientific objectives, the sensor's calibration must be constantly monitored, and robust atmospheric corrections and bio-optical algorithms must be developed. The plan incorporates a multi-faceted approach to sensor calibration using a combination of vicarious (based on in situ observations) and onboard calibration techniques. Because of budget constraints and the limited availability of ship resources, the development of the operational algorithms (atmospheric and bio-optical) will rely heavily on collaborations with the Earth Observing System (EOS), the Moderate Resolution Imaging Spectrometer (MODIS) oceans team, and projects sponsored by other agencies, e.g., the U.S. Navy and the National Science Foundation (NSF). Other elements of the plan include the routine quality control of input ancillary data (e.g., surface wind, surface pressure, ozone concentration, etc.) used in the processing and verification of the level-0 (raw) data to level-1 (calibrated radiances), level-2 (derived products), and level-3 (gridded and averaged derived data) products

Nutrition Can Modulate the Toxicity of Environmental Pollutants: Implications in Risk Assessment and Human Health

Background: The paradigm of human risk assessment includes many variables that must be viewed collectively in order to improve human health and prevent chronic disease. The pathology of chronic diseases is complex, however, and may be influenced by exposure to environmental pollu-tants, a sedentary lifestyle, and poor dietary habits. Much of the emerging evidence suggests that nutrition can modulate the toxicity of environmental pollutants, which may alter human risks associated with toxicant exposures

Using Nutrition for Intervention and Prevention against Environmental Chemical Toxicity and Associated Diseases

BACKGROUND: Nutrition and lifestyle are well-defined modulators of chronic diseases. Poor dietary habits (such as high intake of processed foods rich in fat and low intake of fruits and vegetables), as well as a sedentary lifestyle clearly contribute to today’s compromised quality of life in the United States. It is becoming increasingly clear that nutrition can modulate the toxicity of environmental pollutants. OBJECTIVES: Our goal in this commentary is to discuss the recommendation that nutrition should be considered a necessary variable in the study of human disease associated with exposure to environmental pollutants. DISCUSSION: Certain diets can contribute to compromised health by being a source of exposure to environmental toxic pollutants. Many of these pollutants are fat soluble, and thus fatty foods often contain higher levels of persistent organics than does vegetable matter. Nutrition can dictate the lipid milieu, oxidative stress, and antioxidant status within cells. The modulation of these parameters by an individual’s nutritional status may have profound affects on biological processes, and in turn influence the effects of environmental pollutants to cause disease or dysfunction. For example, potential adverse health effects associated with exposure to polychlorinated biphenyls may increase as a result of ingestion of certain dietary fats, whereas ingestion of fruits and vegetables, rich in antioxidant and anti-inflammatory nutrients or bioactive compounds, may provide protection. CONCLUSIONS: We recommend that future directions in environmental health research explore this nutritional paradigm that incorporates a consideration of the relationships between nutrition and lifestyle, exposure to environmental toxicants, and disease. Nutritional interventions may provide the most sensible means to develop primary prevention strategies of diseases associated with many environmental toxic insults

Diagnostic and Prognostic Significance of Complement in Patients with Alcohol-associated Hepatitis

BACKGROUND and AIMS: Given the lack of effective therapies and high mortality in acute alcohol-associated hepatitis (AH), it is important to develop rationally-designed biomarkers for effective disease management. Complement, a critical component of the innate immune system, contributes to uncontrolled inflammatory responses leading to liver injury, but is also involved in hepatic regeneration. Here we investigated if a panel of complement proteins and activation products would provide useful biomarkers for severity of AH and aid in predicting 90 days mortality. APPROACH and RESULTS: Plasma samples collected at time of diagnosis from 254 patients with moderate and severe AH recruited from four medical centers and 31 healthy individuals were used to quantify complement proteins by ELISA and Luminex arrays. Components of the classical and lectin pathways, including complement factors C2, C4b and C4d, as well as complement factor I (CFI) and C5, were reduced in AH patients compared to healthy individuals. In contrast, components of the alternative pathway, including complement factor Ba (CFBa) and factor D (CFD), were increased. Markers of complement activation were also differentially evident, with C5a increased and the soluble terminal complement complex (sC5b9) decreased in AH. Mannose binding lectin (MBL), C4b, CFI, C5 and sC5b9 were negatively correlated with model for end-stage liver disease (MELD) score, while CFBa and CFD were positively associated with disease severity. Lower CFI and sC5b9 were associated with increased 90-day mortality in AH. CONCLUSIONS: Taken together, these data indicate that AH is associated with a profound disruption of complement. Inclusion of complement, especially CFI and sC5b9, along with other laboratory indicators, could improve diagnostic and prognostic indications of disease severity and risk of mortality for AH patients

Somali Current rings in the eastern Gulf of Aden

Author Posting. © American Geophysical Union, 2006. This article is posted here by permission of American Geophysical Union for personal use, not for redistribution. The definitive version was published in Journal of Geophysical Research 111 (2006): C09039, doi:10.1029/2005JC003338.New satellite-based observations reveal that westward translating anticyclonic rings are generated as a portion of the Somali Current accelerates northward through the Socotra Passage near the mouth of the Gulf of Aden. Rings thus formed exhibit azimuthal geostrophic velocities exceeding 50 cm/s, are comparable in overall diameter to the width of the Gulf of Aden (250 km), and translate westward into the gulf at 5–8 cm/s. Ring generation is most notable in satellite ocean color imagery in November immediately following the transition between southwest (boreal summer) and northeast (winter) monsoon regimes. The observed rings contain anomalous fluid within their core which reflects their origin in the equator-crossing Somali Current system. Estimates of Socotra Passage flow variability derived from satellite altimetry provide evidence for a similar ring generation process in May following the winter-to-summer monsoon transition. Cyclonic recirculation eddies are observed to spin up on the eastern flank of newly formed rings with the resulting vortex pair translating westward together. Recent shipboard and Lagrangian observations indicate that vortices of both sign have substantial vertical extent and may dominate the lateral circulation at all depths in the eastern Gulf of Aden.This investigation is a component of the Red Sea Outflow Experiment (REDSOX) sponsored by the U.S. National Science Foundation through grants OCE 98-18464 and OCE 04-24647 to the Woods Hole Oceanographic Institution and OCE 98-19506 and OCE 03-51116 to the University of Miami

A novel framework to study the effect of tree architectural traits on stemflow yield and its consequences for soil-water dynamics

International audienceA novel experimental approach and numerical framework are proposed to study the effect of tree architectural traits on stemflow yield and its effects on soil-water dynamics. The framework includes a data mining workflowemploying information from two experimental steps: (i) evaluation of the effect of tree aboveground architecture on stemflow yield and (ii) quantification of specific parameters for soil-water dynamics with and withoutstemflow. We studied double-funnelling (stemflow and root-induced preferential flow) under three sycamore (Acer pseudoplatanus L.) trees growing on a slope in Scotland during the summer season and measured architecturaltraits. Stemflow yield ranged from 1.3 to 3.8% of the incident rainfall, with funnelling ratios of between 2.2 ± 2.1 and 5.2 ± 3.9. Double-funnelling to a depth of up to 400 mm beneath the soil surface occurred as matrix flow and was significantly and positively correlated with the vertical root distribution. Soil-water dynamics were distinctly different with and without stemflow. Our framework revealed that the number of tree branches, their insertion angle, leaf number, and stem basal diameter influenced stemflow yield within rainfall thresholds of 1.1 and 3.5 mm d-1. The framework also showed that stemflow yield had a negative impact on soil matric suction, while air temperature was the most influential covariate affecting soil-water dynamics, likely due to its strong correlation to evapotranspiration during the summer season. In spite of the study limitations, such as small sample size and differences between individuals, we show that the proposed framework and experimental approach can contribute to our knowledge of how stemflow generated aboveground triggers major responses in soil-water dynamics belowgroun