Section 243 and Bootstrap Sales: The Dilemma of the Corporate Shareholder

The differences in the tax treatment of dividends and redemptions, the tax goals of individual and corporate shareholders, and the characterizations given corporate distributions by the Internal Revenue Service and the courts have combined to create over-whelming confusion for corporate bootstrap sales. The purpose of this Note is to formulate a rational, consistent approach to the tax treatment of corporate bootstrap sales. Accordingly, this Note initially will discuss various lines of cases governing the possible tax treatment of the seller in a bootstrap acquisition. Special emphasis will be placed on the recent line of cases that deny section 243 intercorporate dividend treatment to a parent corporation selling the stock of a subsidiary. The rationale of these corporate bootstrap cases will be challenged on both legal and policy grounds. Finally, this Note will propose that a parent should be permitted to receive a tax-free intercorporate dividend in an amount not in excess of its allocable portion of the undistributed after-tax income reported by the subsidiary since the parent\u27s acquisition of control

A role for Sp and helix-loop-helix transcription factors in the regulation of the human Id4 gene promoter activity.

Abstract Id family helix-loop-helix (HLH) proteins are involved in the regulation of proliferation and differentiation of several cell types. To identify cis- and trans-acting factors that regulate Id4 gene expression, we have analyzed the promoter regulatory sequences of the human Id4 gene in transient transfections and gel mobility shift assays. We have identified two functional elements, both located downstream from the TATA motif, that control Id4 promoter activity. One element contains a consensus E-box, and we demonstrated that the protein complex binding to the E-box contains the bHLH-zip upstream stimulatory factor (USF) transcription factor. Enforced expression of USF1 leads to E-box-mediated stimulation of promoter activity. The E-box also mediated stimulatory effects of several bHLH transcription factors, and co-expression of Id4 blocked the stimulatory effect mediated by the bHLH factors. A second element is a GA motif, located downstream from the transcriptional start sites, mutation of which resulted in a 20-fold increase in transcriptional activity. Gel-shift analysis and transfections into DrosophilaSchneider SL2 cells showed that the repressor element is recognized by both Sp1 and Sp3 factors. These data suggest that Id4 transcription control is highly complex, involving both negative and positive regulatory elements, including a novel inhibitory function exerted by Sp1 and Sp3 transcription factors

Does orthopaedic resident efficiency improve with respect to decreased fluoroscopic times in tibial intramedullary nailing? A measure of an ACGME milestone

Background: Intramedullary nailing of tibial fractures is a surgical milestone from the Accreditation Council for Graduate Medical Education (ACGME). Our purpose was to evaluate if fluoroscopic time decreased with increasing resident experience and could be used as a measure of this milestone. Methods: Current Procedural Terminology (CPT) codes were used to identify patients who underwent intramedullary nailing of tibial shaft fractures under the direction of fellowship-trained trauma attending staff. The data collected included patient demographics, fracture classification, fluoroscopic imaging total time, and the post-graduate years (PGY) of orthopaedic residency of the operating resident. Exclusions of patients included concomitant fluoroscopic procedures, inadequate records, or surgeries involving primary assisting residents with less than PGY-2 experience. We compared overall groups between half years and looked at individual resident years for each of the continuous variables. Results: When residents were grouped as senior (PGY-4 and PGY-5) or junior (PGY-2 and PGY-3), seniors used significantly less fluoroscopy than juniors (207.39 sec vs. 258.30 sec, P=0.018). In the first half of the academic year, PGY-2 residents completed tibial nailing slowest in terms of fluoroscopic usage (P=0.003). PGY-4 residents completed tibial nailing faster in terms of fluoroscopic usage than other years (P=0.031). In the second half of the academic year, PGY-5 residents used significantly less fluoroscopy than PGY-2 residents (P=0.035). Conclusions: As the ACGME currently has no measurement for resident progress and efficiency regarding tibial shaft intramedullary nailing, our data indicate that fluoroscopic measurements may be useful in assessing resident proficiency

Signaling through Ras is essential for ret oncogene-induced cell differentiation in PC12 cells.

Specific germline mutations of the receptor tyrosine kinase, Ret, predispose to multiple endocrine neoplasia types 2A and 2B and familial medullary thyroid carcinoma. The mechanisms by which different Ret isoforms (Ret-2A and Ret-2B) cause distinct neoplastic diseases remain largely unknown. On the other hand, forced expression of these mutated versions of Ret induces the rat pheochromocytoma cell line, PC12, to differentiate. Here we used an inducible vector encoding a dominant-negative Ras (Ras p21(N17)) to investigate the contributions of the Ras pathway to the phenotype induced in PC12 cells by the expression of either Ret-2A or Ret-2B mutants. We show that the Ret-induced molecular and morphological changes are both mediated by Ras-dependent pathways. However, even though inhibition of Ras activity was sufficient to revert Ret-induced differentiation, the kinetics of morphological reversion of the Ret-2B- was more rapid than the Ret-2A- transfected cells. Further, we show that in Ret-transfected cells the suc1- associated neurotrophic factor-induced tyrosine phosphorylation target, SNT, is chronically phosphorylated in tyrosine residues, and associates with the Sos substrate. These results indicate the activation of the Ras cascade as an essential pathway triggered by the chronic active Ret mutants in PC12 cells. Moreover, our data indicate SNT as a substrate for both Ret mutants, which might mediate the activation of this cascade

The impact of a virtual orthopaedic surgery symposium on medical students: Increasing awareness and knowledge of the field

UNLABELLED: Orthopaedic surgery has become an increasingly popular field of residency training for medical students. Many institutions offer elective time to explore areas of interest through clinical rotations and research; however, most of these opportunities are reserved for senior medical students. The purpose of this study was to evaluate the impact of a dedicated medical student orthopaedic surgery symposium to increase awareness about the field and to assess students\u27 interest and knowledge of orthopaedic surgery before and after the symposium. METHODS: Medical students were invited to submit orthopaedic surgery-related research to a free, 1-day virtual symposium held in April 2022. Abstracts were reviewed and selected from 9 different orthopaedic surgery subspecialty categories. Survey assessments were sent to medical students to complete before and after the symposium. The surveys included questions related to participant demographics as well as interest and knowledge about the field of orthopaedic surgery. Statistical analyses were completed to compare the participants\u27 responses before and after the symposium. RESULTS: In total, 962 medical students registered for the 4-hour symposium. Of these, 58.5% completed the presymposium survey and 48.0% completed the postsymposium survey. 13.3% of the respondents reported being very knowledgeable about the various orthopaedic surgery subspecialties before the symposium, which increased to 18.4% after the symposium. 46.9% of the participants stated that they were knowledgeable about the daily life of an orthopaedic surgery resident before the symposium, which increased to 67.3% after the symposium. Similarly, the percentage of respondents who reported that they were very knowledgeable about the residency match process increased from 12.2% presymposium to 22.4% postsymposium. CONCLUSIONS: As interest in pursuing a career in orthopaedic surgery increases, medical students will continue to seek information, mentorship, and opportunities to present their research in preparation for residency applications. Our study demonstrated that a large-scale, national, virtual orthopaedic surgery symposium provided a platform to augment medical students\u27 knowledge of the field, present their research, and interact with faculty members. LEVEL OF EVIDENCE: Level V

Distributed-memory multi-GPU block-sparse tensor contraction for electronic structure (revised version)

Many domains of scientific simulation (chemistry, condensed matter physics, data science) increasingly eschew dense tensors for block-sparse tensors, sometimes with additional structure (recursive hierarchy, rank sparsity, etc.). Distributed-memory parallel computation with block-sparse tensorial data is paramount to minimize the time-tosolution (e.g., to study dynamical problems or for real-time analysis) and to accommodateproblems of realistic size that are too large to fit into the host/device memory of a single node equipped with accelerators. Unfortunately, computation with such irregular data structures is a poor match to the dominant imperative, bulk-synchronous parallel programming model. In this paper, we focus on the critical element of block-sparse tensor algebra, namely binary tensor contraction, and report on an efficient and scalable implementation using the task-focused PaRSEC runtime. High performance of the block-sparse tensor contraction on the Summit supercomputer is demonstrated for synthetic data as well as for real data involved in electronic structure simulations of unprecedented size.Les tenseurs creux par blocs (block-sparse) sont présents dans de nombreux domaines scientifiques. Ce rapport étudie la parallélisation d’un noyau de contraction essentiel pour la manipulation de tels tenseurs, qui peut se matérialiser sous forme d’un produit de matrices C ← C + AB, où les trois matrices ont une structure creuse par blocs, où les tuiles de A et B sont de tailles hétérogènes, et où B est carrée de taille n, alors que A et C sont rectangulaires de taille m × n avec m << n. Nous proposons une implémentation sur la plate-forme Summit à mémoire distribuée, où chaque nœud est équipé de plusieurs GPUs, au sein de l’environnement de tâches PaRSEC. Nous obtenons de bonnes performances pour des problèmes de taille inégalées à ce jour

Symbiotic modeling: Linguistic Anthropology and the promise of chiasmus

Reflexive observations and observations of reflexivity: such agendas are by now standard practice in anthropology. Dynamic feedback loops between self and other, cause and effect, represented and representamen may no longer seem surprising; but, in spite of our enhanced awareness, little deliberate attention is devoted to modeling or grounding such phenomena. Attending to both linguistic and extra-linguistic modalities of chiasmus (the X figure), a group of anthropologists has recently embraced this challenge. Applied to contemporary problems in linguistic anthropology, chiasmus functions to highlight and enhance relationships of interdependence or symbiosis between contraries, including anthropology’s four fields, the nature of human being and facets of being human

Subsidence and Nonunion after Anterior Cervical Interbody Fusion Using a Stand-Alone Polyetheretherketone (PEEK) Cage

Background: The purposes of the present study are to evaluate the subsidence and nonunion that occurred after anterior cervical discectomy and fusion using a stand-alone intervertebral cage and to analyze the risk factors for the complications.Methods: Thirty-eight patients (47 segments) who underwent anterior cervical fusion using a stand-alone polyetheretherketone (PEEK) cage and an autologous cancellous iliac bone graft from June 2003 to August 2008 were enrolled in this study. The anterior and posterior segmental heights and the distance from the anterior edge of the upper vertebra to the anterior margin of the cage were measured on the plain radiographs. Subsidence was defined as ≥ a 2 mm (minor) or 3 mm (major) decrease of the segmental height at the final follow-up compared to that measured at the immediate postoperative period. Nonunion was evaluated accordingto the instability being ≥ 2 mm in the interspinous distance on the flexion-extension lateral radiographs.Results: The anterior and posterior segmental heights decreased from the immediate postoperative period to the final follow-up at 1.33 ± 1.46 mm and 0.81 ± 1.27 mm, respectively. Subsidence ≥ 2 mm and 3 mm were observed in 12 segments (25.5%) and 7 segments (14.9%), respectively. Among the expected risk factors for subsidence, a smaller anteroposterior (AP) diameter (14 mm vs. 12 mm) of cages (p = 0.034; odds ratio [OR], 0.017) and larger intraoperative distraction (p = 0.041; OR, 3.988) had a significantlyhigher risk of subsidence. Intervertebral nonunion was observed in 7 segments (7/47, 14.9%). Compared with the union group, the nonunion group had a significantly higher ratio of two-level fusion to one-level fusions (p = 0.001).Conclusions: Anterior cervical fusion using a stand-alone cage with a large AP diameter while preventing anterior intraoperative over-distraction will be helpful to prevent the subsidence of cages. Two-level cervical fusion might require more careful attention for avoiding nonunion.Keywords: Anterior cervical fusion, PEEK cage, Subsidence, NonunionOAIID:oai:osos.snu.ac.kr:snu2011-01/102/0000004226/3SEQ:3PERF_CD:SNU2011-01EVAL_ITEM_CD:102USER_ID:0000004226EMP_ID:A076317DEPT_CD:801FILENAME:E031T_CiOS-2011_Yang_Subsidence and nonunion after anterior cervical.pdfDEPT_NM:의학과EMAIL:[email protected]_YN:NCONFIRM:

Clinical and radiological evaluation of Trabecular Metal and the Smith–Robinson technique in anterior cervical fusion for degenerative disease: a prospective, randomized, controlled study with 2-year follow-up

A prospective, randomized, controlled study was carried out to compare the radiological and clinical outcomes after anterior cervical decompression and fusion (ACDF) with Trabecular Metal™ (TM) to the traditional Smith–Robinson (SR) procedure with autograft. The clinical results of cervical fusion with autograft from the iliac crest are typically satisfactory, but implications from the donor site are frequently reported. Alternative materials for cervical body interfusion have shown lower fusion rates. Trabecular Metal is a porous tantalum biomaterial with structure and mechanical properties similar to that of trabecular bone and with proven osteoconductivity. As much as 80 consecutive patients planned for ACDF were randomized for fusion with either TM or tricortical autograft from the iliac crest (SR) after discectomy and decompression. Digitized plain radiographic images of 78 (98%) patients were obtained preoperatively and at 2-year follow-up and were subsequently evaluated by two senior radiologists. Fusion/non-fusion was classified by visual evaluation of the A–P and lateral views in forced flexion/extension of the cervical spine and by measuring the mobility between the fused vertebrae. MRI of 20 TM cases at 2 years was successfully used to assess the decompression of the neural structures, but was not helpful in determining fusion/non-fusion. Pain intensity in the neck, arms and pelvis/hip were rated by patients on a visual analog scale (VAS) and neck function was rated using the Neck Disability Index (NDI) the day before surgery and 4, 12 and 24 months postoperatively. Follow-ups at 12 and 24 months were performed by an unbiased observer, when patients also assessed their global outcome. Fusion rate in the SR group was 92%, and in the TM group 69% (P < 0.05). The accuracy of the measurements was calculated to be 2.4°. Operating time was shorter for fusion with TM compared with autograft; mean times were 100 min (SD 18) and 123 min (SD 23), respectively (P = 0.001). The patients’ global assessments of their neck and arm symptoms 2 years postoperatively for the TM group were rated as 79% much better or better after fusion with TM and 75% using autograft. Pain scores and NDI scores were significantly improved in both groups when compared with baseline at all follow-ups, except for neck pain at 1 year for the TM group. There was no statistically significant difference in clinical outcomes between fusion techniques or between patients who appeared radiologically fused or non-fused. There was no difference in pelvic/hip pain between patients operated on with or without autograft. In our study, Trabecular Metal showed a lower fusion rate than the Smith–Robinson technique with autograft after single-level anterior cervical fusion without plating. There was no difference in clinical outcomes between the groups. The operative time was shorter with Trabecular Metal implants