1,596 research outputs found
Radial honeycomb core
Core alleviates many limitations of conventional nacelle construction methods. Radical core, made of metals or nonmetals, is fabricated either by joining nodes and then expanding, or by performing each layer and then joining nodes. Core may also be produced from ribbons or strips with joined nodes or ribbons oriented in longitudinal planes
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Decoding Key Nodes in the Metabolism of Cancer Cells: Sugar & Spice and All Things Nice
In the past 5 years, a convergence of studies has resulted in a broad appreciation in the cancer research community that reprogramming of cellular metabolism may be more central to cancer than appreciated in the past 30 years. The re-emergence of cancer metabolism stems in part from discoveries that a number of common oncogenes and tumor suppressor genes more directly control cell metabolism than previously thought. In addition, a number of what would previously have been called “card-carrying” metabolic enzymes have been identified as human tumor suppressors or oncogenes, causally mutated in a variety of human cancers. This growing appreciation of the role of altered cell metabolism has led to further investigation into the rate-limiting proteins involved in different aspects of the unique metabolism of tumor cells. Targeting cancer metabolism with drugs requires a therapeutic window in which tumor cells, compared to normal tissues, have a greater dependence on specific metabolic enzymes. Themes that have emerged in the past decade of developing oncogene-targeted cancer therapeutics suggest that tumors with distinct oncogenic lesions are likely to require drugs that target distinct metabolic pathways. Ultimately, the hope is that detailed knowledge of oncogene and tumor suppressor gene functions and their effects on metabolism will lead to drug combinations that will be far more effective in treating cancers
\u3cem\u3eWells Fargo & Co. v. U.S.\u3c/em\u3e: A Potential Beginning of The End of The Objective Reasonable Basis Tax Penalty Defense
The Internal Revenue Code (“IRC”) § 6662(a) permits the IRS to impose a twenty-percent (20%) accuracy-related penalty to an underpayment of tax, and there are several different defenses to this penalty depending on the facts of the case and the reason for the penalty.3 One of the most common accuracy-related penalties is the negligence penalty.4 Although there are multiple different reasons for the application of an accuracy-related penalty, only one penalty may be applied for each understatement.5 If a taxpayer faces the negligence penalty, one common defense is that the taxpayer’s return position has a reasonable basis under the relevant authorities.6 Until recently, most courts simply proceeded through a discussion on whether the authorities supported the taxpayer’s return position, and did not even reach whether the taxpayer actually relied on relevant authorities when forming a return position.7 However, over the past few years, several courts have begun to require a subjective actual reliance component to the reasonable basis standard, in addition to the other requirements described under the regulations.
This article explores these concepts more in detail in six parts. Part II introduces the statutory reasonable basis defense, reviewing the applicable regulations9 and the circumstances when the negligence penalty is applied.10 Next, Part III introduces prior case law analyzing the reasonable basis defense, ranging from cases applying a more objective reasonable basis defense, and several courts applying a subjective11 component to the reasonable basis defense. Until recently, many courts did not examine whether a taxpayer actually relied on the authorities listed to support its position, but instead looked to if the taxpayer’s return position was objectively supported by the relevant authorities. Part IV examines Wells Fargo & Co. v. United States in detail including the facts of the case, the holding on the tax in which the court struck down Wells Fargo’s STARS transaction12, and the court’s reasoning that actual reliance is required as part of the reasonable basis defense.13 The court looked at the broader statutory and case law framework, as well as the definition of “base,” and determined the reasonable basis standard also required a subjective actual reliance component.14 Further, the court determined that a part of the STARS transaction did not have any purpose other than tax savings.15 Part V examines how other courts may view this holding going forward and discusses how the majority incorrectly concluded that under the reasonable basis defense a taxpayer’s return position must not only be supported by one or more relevevant authorities, but the taxpayer must also rely on those authorities when contemplating tax decisions.16 In circuits requiring an actual reliance on one or more relevant authorities, taxpayers must document or be able to show that they actually relied on the authorities cited in support of their case, and the return position cannot be a position taken after the return is filed to support the return position. Lastly, Part VI provides an overview of the conclusions reached in this article
Ground Zero: The IRS Attack on Syndicated Conservation Easements
On June 25, 2020, the Internal Revenue Service (“IRS”) announced a settlement initiative (“SI”) to certain taxpayers with pending docketed cases involving syndicated conservation easement (“SCE”) transactions. The SI is the current culmination of a long series of attacks by the IRS against SCE transactions. The IRS has recently found success in the Tax Court against SCEs, but the agency’s overall legal position may be overstated. It is possible that the recent SI is merely an attempt to capitalize on leverage while the IRS has it. Regardless, the current state of the law surrounding SCEs is murky at best. Whether a taxpayer is contemplating the settlement offer, is currently involved in an unaudited SCE transaction, or is considering involvement in an SCE transaction in the future, the road ahead is foggy and potentially treacherous.
This Article attempts to shed light on the obstacles that face SCE transactions. This Article: (1) provides an overview of SCE transactions and the main attacks against them; (2) analyzes each of the IRS’s main attacks and the relevant issues that arise; (3) illustrates the relevant pro-taxpayer and anti-taxpayer cases on each issue; (4) discusses the subsequent considerations that taxpayers need to take into account and the future outlook of SCE; and (5) concludes with a summary of the Article’s findings
NRF2 Rewires Cellular Metabolism to Support the Antioxidant Response
The transcription factor (nuclear factor-erythroid 2 p45-related factor 2, NRF2) is a master regulator of the cellular response to oxidative insults. While antioxidant response enzymes are well-characterized transcriptional targets of NRF2, it is recently becoming clear that NRF2 also supports cellular detoxification through metabolic rewiring to support the antioxidant systems. In this chapter, we discuss the regulation of NRF2 and how NRF2 activation promotes the antioxidant defense of cells. Furthermore, we discuss how reactive oxygen species influence cellular metabolism and how this affects antioxidant function. We also discuss how NRF2 reprograms cellular metabolism to support the antioxidant response and how this functions to funnel metabolic intermediates into antioxidant pathways. This chapter concludes by exploring how these factors may contribute to both normal physiology and disease
A CMOS Synapse Design Implementing Tunable Asymmetric Spike Timing-Dependent Plasticity
A CMOS synapse design is presented which can perform tunable asymmetric spike timing-dependent learning in asynchronous spiking neural networks. The overall design consists of three primary subcircuit blocks, and the operation of each is described. Pair-based Spike Timing-Dependent Plasticity (STDP) of the entire synapse is then demonstrated through simulation using the Cadence Virtuoso platform. Tuning of the STDP curve learning window and rate of synaptic weight change is possible using various control parameters. With appropriate settings, it is shown the resulting learning rule closely matches that observed in biological systems
An exploration of occupation in nursing home residents with dementia
Objectives: This study evaluated the sitting room environment of two nursing homes
in Ireland, using interactive occupation and social engagement as outcome measures
and defining these rooms as occupational spaces.
Method: Snapshot observational recordings were made in the main sitting rooms
during the periods of time when the rooms were in most active use. Narrative
information was also recorded.
Results: Residents were more likely to occupy their time in the main sitting room
passively, rather than in interactive occupation and social engagement. The nursing
home residents with dementia spent approximately 70% of their daily time in the
main sitting room areas in states of occupational disengagement.
Discussion: Additional insight is provided through pragmatic narrative descriptions
of the functioning of the main sitting room environment in terms of interactive
occupation and social engagement.
Relevance: The research study demonstrates a methodology for evaluating the
sitting room areas of a care environment, using interactive occupation and social
engagement as outcome measures,which can be used for descriptive and comparative
insights into the performance of care environments
The tyrosine-phosphorylated hepatocyte growth factor/scatter factor receptor associates with phosphatidylinositol 3-kinase.
The receptor for hepatocyte growth factor, also known as scatter factor (HGF/SF), has recently been identified as the 190-kDa heterodimeric tyrosine kinase encoded by the MET proto-oncogene (p190MET). The signaling pathway(s) triggered by HGF/SF are unknown. In A549 cells, a lung epithelial cell line, nanomolar concentrations of HGF/SF induced tyrosine phosphorylation of the p190MET receptor. The autophosphorylated receptor coprecipitated with phosphatidylinositol 3-kinase (PI 3-kinase) activity. In GTL16 cells, a cell line derived from a gastric carcinoma, the p190MET receptor, overexpressed and constitutively phosphorylated on tyrosine, coprecipitated with PI 3-kinase activity and with the 85-kDa PI 3-kinase subunit. In these cells activation of protein kinase C or the increase of intracellular [Ca2+] inhibits tyrosine phosphorylation of the p190MET receptor as well as the association with both PI 3-kinase activity and the 85-kDa subunit of the enzyme. In an in vitro assay, tyrosine phosphorylation of the immobilized p190MET receptor was required for binding of PI 3-kinase from cell lysates. These data strongly suggest that the signaling pathway activated by the HGF/SF receptor includes generation of D-3-phosphorylated inositol phospholipids
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