The Likely Source: An Unexplored Weakness in the Net Worth Method of Proof

The government will often suspect a taxpayer of tax evasion if it discovers that the taxpayer\u27s net worth has increased and that the taxpayer did not report the full amount of the increase as taxable income. If the government can establish a likely source for the increase, a jury will be permitted to infer that the taxpayer derived the increase from currently taxable and unreported income. In this article, the author discusses the origins, development, and varied applications of this likely source inference. Then, after critically examining the constitutional underpinnings of the inference, the author argues that the inference is unconstitutional as presently applied by most courts. The author concludes by suggesting how the doctrine can be modified to permit its continued use

Alien Registration- Comisky, Bruno K. (Lewiston, Androscoggin County)

https://digitalmaine.com/alien_docs/26933/thumbnail.jp

Permeability Prediction in Tight Carbonate Rocks using Capillary Pressure Measurements

The prediction of permeability in tight carbonate reservoirs presents ever more of a challenge in the hydrocarbon industry today. It is the aim of this paper to ascertain which models have the capacity to predict permeability reliably in tight carbonates, and to develop a new one, if required. This paper presents (i) the results of laboratory Klinkenberg-corrected pulse decay measurements of carbonates with permeabilities in the range 65 nD to 0.7 mD, (ii) use of the data to assess the performance of 16 permeability prediction models, (iii) the development of an improved prediction model for tight carbonate rocks, and (iv) its validation using an independent data set. Initial measurements including porosity, permeability and mercury injection capillary pressure measurements (MICP) were carried out on a suite of samples of Kometan limestone from the Kurdistan region of Iraq. The prediction performance of sixteen different percolation-type and Poiseuille-type permeability prediction models were analysed with the measured data. Analysis of the eight best models is included in this paper and the analysis of the remainder is provided in supplementary material. Some of the models were developed especially for tight gas sands, while many were not. Critically, none were developed for tight gas carbonates. Predictably then, the best prediction was obtained from the generic model and the RGPZ models (R2 = 0.923, 0.920 and 0.915, respectively), with other models performing extremely badly. In an attempt to provide a better model for use with tight carbonates, we have developed a new model based on the RGPZ theoretical model by adding an empirical scaling parameter to account for the relationship between grain size and pore throat size in carbonates. The generic model, the 28 new RGPZ Carbonate model and the two original RGPZ models have been tested against independent data from a suite of 42 samples of tight Solnhofen carbonates. All four models performed very creditably with the generic and the new RGPZ Carbonate models performing well (R2 = 0.840 and 0.799, respectively). It is clear from this study that the blind application of conventional permeability prediction techniques to carbonates, and particularly to tight carbonates, will lead to gross errors and that the development of new methods that are specific to tight carbonates is unavoidable

The Impact of Context on Affective Norms: A Case of Study With Suspense

The emotional response to a stimulus is typically measured in three variables called valence, arousal and dominance. Based on such dimensions, Bradley and Lang (1999) published the Affective Norms for English Words (ANEW), a corpus of affective ratings for 1,034 non-contextualized words. Expanded and adapted to many languages, ANEW provides a corpus to evaluate and to predict human responses to different stimuli, and it has been used in a number of studies involving analysis of emotions. However, ANEW seems not to appropriately predict affective responses to concepts when these are contextualized in certain situational backgrounds, in which words can have different connotations from those in non-contextualized scenarios. These contextualized affective norms have not been sufficiently contrasted yet because the literature does not provide a corpus of the ANEW list in specific contexts. On this basis, this paper reports on the creation of a new corpus of affective norms for the original 1,034 ANEW words in a particular context (a fictional scene of suspense). An extensive quantitative data analysis comparing both corpora was carried out, confirming that the affective ratings are highly influenced by the context

The natural exclusion of red deer from large boulder grazing refugia and the consequences for saxicolous bryophyte and lichen ecology

Large boulder grazing refugia permitted comparison of saxicolous bryophyte and lichen assemblages with those boulder tops accessible to red deer (Cervus elaphus) on a sporting estate in northwest Scotland. Plant succession was predicted to occur unchecked by grazing on the tops of these large boulders with cascading effects on bryophytes and lichens—assuming boulders had been in place over the same time period. Fifty pairs of boulders (one ≥2 m and the other accessible to red deer) were selected at random from various locations below north-facing crags. Percentage cover of each bryophyte and lichen species was estimated from three randomly placed quadrats on each boulder top. Due consideration was given to the influence of island biogeography theory in subsequent model simplification. Mean shrub cover and height, leaf-litter, bryophyte cover and bryophyte species richness were significantly higher within quadrats on large boulder tops that naturally excluded red deer. Lichen cover and lichen species richness were significantly higher on boulder tops accessible to red deer. Lichen cover was in a significant negative relationship with bryophyte cover, shrub cover and litter cover. Bryophyte cover showed a significant positive relationship with shrub height but there was an optimum shrub cover. Natural exclusion of red deer from the tops of large boulders has facilitated plant succession. The results suggest that grazing arrests the lithosere on boulder tops accessible to red deer at an early plagioclimax favouring saxicolous lichens. The results are relevant to situations where red deer might be excluded from boulder fields that hold lichen assemblages of conservation value

What is eSports and why do people watch it?

PurposeThe purpose of this paper is to investigate why do people spectate eSports on the internet. The authors define eSports (electronic sports) as “a form of sports where the primary aspects of the sport are facilitated by electronic systems; the input of players and teams as well as the output of the eSports system are mediated by human-computer interfaces.” In more practical terms, eSports refer to competitive video gaming (broadcasted on the internet).Design/methodology/approachThe study employs the motivations scale for sports consumption which is one of the most widely applied measurement instruments for sports consumption in general. The questionnaire was designed and pre-tested before distributing to target respondents (n=888). The reliability and validity of the instrument both met the commonly accepted guidelines. The model was assessed first by examining its measurement model and then the structural model.FindingsThe results indicate that escapism, acquiring knowledge about the games being played, novelty and eSports athlete aggressiveness were found to positively predict eSport spectating frequency.Originality/valueDuring recent years, eSports (electronic sports) and video game streaming have become rapidly growing forms of new media in the internet driven by the growing provenance of (online) games and online broadcasting technologies. Today, hundreds of millions of people spectate eSports. The present investigation presents a large study on gratification-related determinants of why people spectate eSports on the internet. Moreover, the study proposes a definition for eSports and further discusses how eSports can be seen as a form of sports.</jats:sec

Determining crystal structures through crowdsourcing and coursework

We show here that computer game players can build high-quality crystal structures. Introduction of a new feature into the computer game Foldit allows players to build and real-space refine structures into electron density maps. To assess the usefulness of this feature, we held a crystallographic model-building competition between trained crystallographers, undergraduate students, Foldit players and automatic model-building algorithms. After removal of disordered residues, a team of Foldit players achieved the most accurate structure. Analysing the target protein of the competition, YPL067C, uncovered a new family of histidine triad proteins apparently involved in the prevention of amyloid toxicity. From this study, we conclude that crystallographers can utilize crowdsourcing to interpret electron density information and to produce structure solutions of the highest quality