Pinch-Hitting for the IRS: Second Circuit Adopts Phantom Regulations to Curb a Monster Abuse of Financial Derivatives

In Estate of McKelvey v. Commissioner, the Second Circuit Court of Appeals adopted the IRS’s position that probability analysis should be employed to determine that the taxpayer’s particular performance under the terms of a financial instrument was “virtually certain.” However, the IRS had steadfastly refused to promulgate regulations that, under a statutory delegation of authority to issue regulations to interpret and enforce the statute, could have administratively imposed that outcome

Time to Prune the Flora--Procedural Due Process, the Full Payment Rule and Assessable Penalties: Larson v. United States

In Larson v. United States, the Second Circuit Court of Appeals rejected the opportunity to limit the scope of the Flora “full payment” rule when its strict application in the instant case foreclosed judicial review of the underlying tax controversy. As a result, the decision rubberstamped the IRS’s imposition of assessable penalties without any meaningful judicial review of those actions. The Article argues that the court’s decision to blindly apply the full payment rule, without considering any form of a hardship exception, effectively denied John Larson his right to due process of law as guaranteed by the Fifth Amendment to the United States Constitution

Quantum Gravity - Testing Time for Theories

The extreme smallness of both the Planck length, on the one side, and the ratio of the gravitational to the electrical forces between, say, two electrons, on the other side has led to a widespread belief that the realm of quantum gravity is beyond terrestrial experiments. A series of classical and quantum arguments are put forward to dispel this view. It is concluded that whereas the smallness of the Planck length and the ratio of gravitational to electrical forces, does play its own essential role in nature, it does not make quantum gravity a science where humans cannot venture to probe her secrets. In particular attention is drawn to the latest neutron and atomic interferometry experiments, and to gravity wave interferometers. The latter, as Giovanni Amelino-Camelia argues [Nature 398, 216 (1999)], can be treated as probes of space-time fuzziness down to Planck length for certain quantum-gravity models

Electromagnetic analysis and performance comparison of fully 3D-printed antennas

In this work, the possibility of directly prototyping antennas by exploiting additive manufacturing 3D-printing technology is investigated. In particular, the availability of printable filaments with interesting conductive properties allows for printing of even the antenna conductive elements. Three samples of a 2.45 GHz microstrip patch antenna have been 3D-printed by using different approaches and materials, and their performance evaluated and compared. In particular, the same dielectric substrate printed in polylactic acid (PLA) has been adopted in all cases, whilst copper tape and two different conductive filaments have been used to realize the conductive parts of the three antenna samples, respectively. Even if an expected radiation efficiency reduction has been observed for the conductive filament case, the comparative analysis clearly demonstrates that 3D-printing technology can be exploited to design working fully-printed antennas, including the conductive parts

You'll Never Walk Alone:The Effect of Moral Support on Performance

This study presents evidence on the role of moral support on performance in a competitive environment. We take advantage of an unusual change in the Argentinean football legislation. In August 2013, as a matter of National security, the Argentinean government forced all the teams of the first division to play their games with only home team supporters. Supporters of the visiting teams were not allowed to be in stadiums during league games. We estimate the effect of this exogenous variation of supporters on team performance, and we find that visiting teams are, on average, about 20% more likely to lose without their supporters. Moreover, we find that the lack of supporters of the visiting team increased the score differential between the home team and the visitor. The effect of the ban is stronger for big teams, who have the highest number of supporters when playing away. In addition, we find no evidence of changes of referees' decisions due to the ban, suggesting that the effect on team performance is due to the loss of moral support rather than a change in referees hostility. As placebo test, we run the analysis using contemporaneous cup matches, where the visiting team supporters were allowed to attend. We find no effect of the ban on the cup games, which provides additional empirical support to our findings. Our results offer unique and novel empirical evidence of the importance on moral support on performance

All you Need is Love:The Effect of Moral Support on Performance (Revision of CentER DP 2018-026)

This study presents unique empirical evidence on the importance of moral support for performance. We take advantage of an unusual change in Argentinean football legislation. In August 2013, as a matter of National security, the Argentinean government forced all teams in the first division to play their games with only home team supporters. Supporters of visiting teams were not allowed to be in stadiums during league games. We estimate the effect of this exogenous variation of supporters on team performance, and find that visiting teams are, on average, about 20% more likely to lose without the presence of their supporters. As a counterfactual experiment, we run the analysis using contemporaneous cup games, where the visiting team supporters were allowed to attend, and find no effect of the ban on those games. Moreover, the ban does not affect the decisions of referees, the lineups or the market value of the teams, suggesting that the effect on team performance is due to the loss of moral support rather than other factors. Finally, we find that moral support is more relevant, and often pivotal, when there is balance of power between the two teams, suggesting that moral support compensates the power of monetary resources. This paper provides a proof of concept of moral support as an important non-monetary resource, even in settings with high monetary incentives

Evidence on Problematic Online Gaming and Social Anxiety over the Past Ten Years: a Systematic Literature Review

Purpose of Review: The present study aimed to review the literature concerning the relationship between problematic online gaming (POG) and social anxiety, taking into account the variables implicated in this relationship. This review included studies published between 2010 and 2020 that were indexed in major databases with the following keywords: Internet gaming, disorder, addiction, problematic, social phobia, and social anxiety. Recent Findings: In recent years, scientific interest in POG has grown dramatically. Within this prolific research field, difficulties associated with social anxiety have been increasingly explored in relation to POG. Indeed, evidence showed that individuals who experience social anxiety are more exposed to the risk of developing an excessive or addictive gaming behavior. Summary: A total of 30 studies satisfied the initial inclusion criteria and were included in the present literature review. Several reviewed studies found a strong association between social anxiety and online gaming disorder. Furthermore, the relationships among social anxiety, POG, age, and psychosocial and comorbid factors were largely explored. Overall, the present review showed that socially anxious individuals might perceive online video games as safer social environments than face-to-face interactions, predisposing individuals to the POG. However, in a mutually reinforcing relationship, individuals with higher POG seem to show higher social anxiety. Therefore, despite online gaming might represent an activity able to alleviate psychopathological symptoms and/or negative emotional states, people might use online gaming to counterbalance distress or negative situations in everyday life, carrying out a maladaptive coping strategy

Oral mucositis: a survey on changes in the proteomic profile

Objectives. Oral mucositis is the most severe complication of anticancer therapy. It occurs in 40-85% of patients during chemotherapy and radiotherapy but also in patients who have undergone hematopoietic stem cell transplantation. The symptoms for oral mucositis are burning and severe pain oral, spontaneous bleeding, dysphagia, dysarthria and odynophagia; especially pain and burning sensation on swallowing contribute to decreased quality of life for oncologic patients and, in severe cases, may also force the patient to feed parenterally (1). Furthermore, if the mucositis is severe it can lead to partial or complete interruption of radiotherapy before completion of the treatment protocol with consequent worsening of the prognosis (2, 3). Dentists must be familiar with the necessary intervents, in order to help the patient during the course of the treatment and prevent the interruption. Certain measures may help minimize the symptoms associated with oral mucositis; however, further research is required, focusing on lesion prevention prior to treatment initiation. To this end, it has been investigated the salivary proteome of cancer patients who developed oral mucositis, post chemotherapy and/or radiotherapy. In addition, we compared the salivary proteome of the same subjects before developing oral mucositis and immediately after the treatment for the mucositis. The analysis was made with SELDI technology. Methods. In the current study, 55 saliva samples of patients suffering from different types of cancer were analyzed. The saliva was collected in three times: before the development of mucositis, when it was diagnosed and after the resolution of this pathology. All samples were analyzed by SELDI-TOF/MS analysis. It was possible to create cluster peaks in spectra obtained using BIORAD DataManagerTM software (Ver 3.5). Results. From this analysis we identified a list of differently expressed mass peaks (clusters). We have selected some significant peaks in a range of values between 3000 m/z 15000 m/z. In particular, five were found to be differentially expressed: 3343, 3486, 3732, 4132 and 4786 m/z. The analysis of the cluster, we evaluated different patterns of peaks in the three groups; some of these were up regulated, as the peak 3732 m/z in samples pre mucositis, and down regulated, such as the 7101 m/z in the samples pre mucositis. It is noted, moreover, an important increase of the peak 4132 m/z in samples of mucositis. Conclusions. Oral mucositis is one of the most frequent complications of cancer therapies. It is, therefore, extremely important that the mucositis is prevented whenever possible, or at least treated to reduce its severity and possible complications. Knowing the salivary proteome and its variations in a state of pre mucositis, mucositis and post mucositis can be useful in order to intervene with preventive tools and better therapies. The association of the peaks 3343, 3486, 3732, 4132 and 4786 m / z, in particular the increase in expression of the peak 4132 m / z in samples of mucositis makes us think that it can be used as biomarker of this condition. Therefore, if these data will be confirmed on a larger series of patients could identify these proteins and study of targeted therapies. Furthermore, it would be helpful to understand whether these variations are associated with a particular chemotherapy and evaluate longer available cancer therapies replacement

Upgrading wineries to biorefineries within a Circular Economy perspective: An Italian case study

In the challenge of transforming waste into useful products that can be re-used in a circular perspective, Italian wine industry can represent a suitable model for the application of the bioeconomy principles, including the valorisation of the agricultural and food waste. In the present study, a comprehensive environmental assessment of the traditional production of wine was performed and the potentiality of a biorefinery system, based on winery waste and aimed at recovering useful bio-based products, such as grapeseed oil and calcium tartrate, was examined through Life Cycle Assessment (LCA). The wine company "I Borboni", producing Asprinio wine in the Campania Region (Italy), was proposed as a case study. The hotspots of the linear production system were identified and the bottling phase, in particular the production of packaging glass, resulted to contribute to the generation of impacts at 63%, on average, versus 14.3% of the agricultural phase and 22.7% of the vinification phase. The LCA results indicated human carcinogenic toxicity, freshwater eutrophication and fossil resource scarcity impact categories as the most affected ones, with normalized impacts amounting to 9.22E-03, 3.89E-04 and 2.64E-04, respectively. Two side production chains (grapeseed oil and tartrate production) were included and circular patterns were designed and introduced in the traditional production chain with the aim of valorising the winery residues and improving the overall environmental performance. By implementing the circular approach, environmental impacts in the global warming, freshwater eutrophication and mineral resource scarcity impact categories, in particular, resulted three times lower than in the linear system. The results achieved demonstrated that closing the loops in the wine industry, through the reuse of bio-based residues alternatively to fossil-based inputs within the production process, and integrating the traditional production system with new side production chains led to an upgrade of the wineries to biorefineries, towards more sustainable production patterns. (c) 2021 Elsevier B.V. All rights reserved