An Empirical Investigation of the Minority Interest and Marketability Discounts In Valuation of Closely Held Stock for Estate and Gift Tax Purposes

The discounts for lack of marketability and minority interest are crucial in reducing the value of transferred interests of closely held companies for estate and gift tax purposes. Because the current highest marginal estate and gift tax rate is 49%, there is a strong inducement for CPAs, Attorneys, Investment Bankers, Financial Planners, and others who value these transfers to accurately gauge the judicially allowed discounts for lack of marketability and minority interests in the valuation of closely held stock. This study examines the relationship between Tax Court determined values for lack of marketability and minority discounts to closely held stock from the compromise percentages. Compromise percentage is defined as the mean of the percentage presented by the adversarial parties, the taxpayer, and the IRS, in a judicial action. Additionally, this relationship is examined across industry classifications. The period investigated covers January 1, 1973 through December 31, 2002. Both regular and memorandum decisions by the Tax Court are analyzed over this thirty-year span. Chi-square analysis is used to determine that the Tax Court determined values are not significantly different than the compromise percentages. Furthermore, this finding does not vary across industries. Regression and chi-squared results are augmented with descriptive statistics

An Empirical Investigation of the Minority Interest and Marketability Discounts In Valuation of Closely Held Stock for Estate and Gift Tax Purposes

The discounts for lack of marketability and minority interest are crucial in reducing the value of transferred interests of closely held companies for estate and gift tax purposes. Because the current highest marginal estate and gift tax rate is 49%, there is a strong inducement for CPAs, Attorneys, Investment Bankers, Financial Planners, and others who value these transfers to accurately gauge the judicially allowed discounts for lack of marketability and minority interests in the valuation of closely held stock. This study examines the relationship between Tax Court determined values for lack of marketability and minority discounts to closely held stock from the compromise percentages. Compromise percentage is defined as the mean of the percentage presented by the adversarial parties, the taxpayer, and the IRS, in a judicial action. Additionally, this relationship is examined across industry classifications. The period investigated covers January 1, 1973 through December 31, 2002. Both regular and memorandum decisions by the Tax Court are analyzed over this thirty-year span. Chi-square analysis is used to determine that the Tax Court determined values are not significantly different than the compromise percentages. Furthermore, this finding does not vary across industries. Regression and chi-squared results are augmented with descriptive statistics

Inheritance of Gray Leaf Spot Resistance in Corn

Gray leaf spot disease, caused by Cercospora zeae-maydis Tehon and Daniels, has become a significant disease in Iowa corn (Zea mays L.) production. Incidence of gray leaf spot has increased with the increased use of conservation tillage practices. The inheritance of resistance to gray leaf spot was studied via use of generation mean analyses for five crosses and via use of 100 S1 progenies developed from an F2 population. Experiments were conducted at two locations that included either natural or artificial inoculation with C. zeae-maydis spores. Additive and dominance effects were significant in nearly all instances. Heritability for gray leaf spot resistance among S1 progenies was 0.78. Because resistance seemed to be determined by additive genetic variation, it seems selection for greater resistance to gray leaf spot can be effective. In all instances, the level of gray leaf spot resistance in single-cross hybrids was improved, whether the single-cross hybrid was produced with either one or both parents having resistance. It seems single-cross hybrids will have adequate levels of resistance to gray leaf spot if at least one of the parents has resistance

Soliton approximation in continuum models of leader-follower behavior

Complex biological processes involve collective behavior of entities (bacteria, cells, animals) over many length and time scales and can be described by discrete models that track individuals or by continuum models involving densities and fields. We consider hybrid stochastic agent-based models of branching morphogenesis and angiogenesis (new blood vessel creation from pre-existing vasculature), which treat cells as individuals that are guided by underlying continuous chemical and/or mechanical fields. In these descriptions, leader (tip) cells emerge from existing branches and follower (stalk) cells build the new sprout in their wake. Vessel branching and fusion (anastomosis) occur as a result of tip and stalk cell dynamics. Coarse-graining these hybrid models in appropriate limits produces continuum partial differential equations (PDEs) for endothelial cell densities that are more analytically tractable. While these models differ in nonlinearity, they produce similar equations at leading order when chemotaxis is dominant. We analyze this leading order system in a simple quasi-one-dimensional geometry and show that the numerical solution of the leading order PDE is well described by a soliton wave that evolves from vessel to source. This wave is an attractor for intermediate times until it arrives at the hypoxic region releasing the growth factor. The mathematical techniques used here thus identify common features of discrete and continuum approaches and provide insight into general biological mechanisms governing their collective dynamics.Comment: 13 pages, 9 figure

Superconducting-coil--resistor circuit with electric field quadratic in the current

It is shown for the first time that the observed [Phys. Lett. A 162 (1992) 105] potential difference Phi_t between the resistor and the screen surrounding the circuit is caused by polarization of the resistor because of the kinetic energy of the electrons of the superconducting coil. The proportionality of Phi_t to the square of the current and to the length of the superconducting wire is explained. It is pointed out that measuring Phi_t makes it possible to determine the Fermi quasimomentum of the electrons of a metal resistor.Comment: 2 pages, 1 figur

Causes of Death on Antiretroviral Therapy: A Post-Mortem Study from South Africa

Background: Mortality in the first months of antiretroviral therapy (ART) is a significant clinical problem in sub-Saharan Africa. To date, no post-mortem study has investigated the causes of mortality in these patients. Methods: HIV-positive adults who died as in-patients at a Johannesburg academic hospital underwent chart-review and ultrasound-guided needle autopsy for histological and microbiological examination of lung, liver, spleen, kidney, bone marrow, lymph node, skin and cerebrospinal fluid. A clinico-pathologic committee considered all available data and adjudicated immediate and contributing causes of death. Results: Thirty-nine adults were enrolled: 14 pre-ART, 15 early-ART (7–90 days), and 10 late-ART (>90 days). Needle sampling yielded adequate specimen in 100% of kidney, skin, heart and cerebrospinal fluid samples, 97% of livers and lungs, 92% of bone marrows, 87% of spleens and 68% of lymph nodes. Mycobacterial infections were implicated in 69% of deaths (26 of 27 of these due to M. tuberculosis), bacterial infections in 33%, fungal infections in 21%, neoplasm in 26%, and non-infectious organ failure in 26%. Immune reconstitution inflammatory syndrome (IRIS) was implicated in 73% of early-ART deaths. Post-mortem investigations revealed previously undiagnosed causes of death in 49% of cases. Multiple pathologies were common with 62% of subjects with mycobacterial infection also having at least one other infectious or neoplastic cause of death. Conclusions: Needle biopsy was efficient and yielded excellent pathology. The large majority of deaths in all three groups were caused by M. tuberculosis suggesting an urgent need for improved diagnosis and expedited treatment prior to and throughout the course of antiretroviral therapy. Complex, unrecognized co-morbidities pose an additional challenge

The relation of plasmacytoid dendritic cells (pDCs) and regulatory t-cells (Tregs) with HPV persistence in HIV-Infected and HIV-Uninfected women

Other than CD4+ count, the immunologic factors that underlie the relationship of HIV/AIDS with persistent oncogenic HPV (oncHPV) and cervical cancer are not well understood. Plasmacytoid dendritic cells (pDCs) and regulatory T-cells (Tregs) are of particular interest. pDCs have both effector and antigen presenting activity and, in HIV-positive patients, low pDC levels are associated with opportunistic infections. Tregs downregulate immune responses, and are present at high levels in HIV-positives. The current pilot study shows for the first time that low pDC and high Treg levels may be significantly associated with oncHPV persistence in both HIV-positive and HIV-negative women. Larger studies are now warranted

Relativistic calculations of the lifetimes and hyperfine structure constants in 67^{67}Zn+^{+}

This work presents accurate {\it ab initio} determination of the magnetic dipole (M1) and electric quadrupole (E2) hyperfine structure constants for the ground and a few low-lying excited states in $^{67}$Zn$^{+}$, which is one of the interesting systems in fundamental physics. The coupled-cluster (CC) theory within the relativistic framework has been used here in this calculations. Long standing demands for a relativistic and highly correlated calculations like CC can be able to resolve the disagreements among the lifetime estimations reported previously for a few low-lying states of Zn$^{+}$. The role of different electron correlation effects in the determination of these quantities are discussed and their contributions are presented.Comment: 9 pages, 1 figure. submitted to J. Phys. B Fast Trac

An observational study of safe and risky practices in funeral homes in South Africa

Background. Funeral home personnel are at risk of exposure to infectious hazards. The high prevalence of infectious diseases in South Africa means that these workers and family members of deceased individuals are vulnerable to infection if proper safety measures and equipment are not used.Objectives. To collect observational information on funeral industry practices in order to assess the safety of handling corpses and exposure to risk that could result in disease transmission.Methods. A cross-sectional study was conducted across two locations from August to October 2015. Funeral homes in Klerksdorp and Soweto were approached. The study team did facility assessments and observed preparation practices, focusing on safety equipment, personal protective equipment (PPE) and contact with hazardous materials. Interviews with funeral home personnel and relatives of the deceased were also conducted.Results. Of the funeral homes, 23.0% (20/87) agreed to participate. A median of 5 personnel (interquartile range 4 - 8) were employed per facility. It was observed that not all PPE was used despite availability. Gloves, aprons and face masks were most commonly worn, and no personnel were observed wearing boots, gowns or plastic sleeves. Funeral homes were located near food outlets, schools and open public spaces, and not all had access to proper biohazardous waste disposal services. Of 5 family members who were interviewed for the study, none reported being willing to partake in the funeral preparation procedure.Conclusions. There is a need to standardise the use of safety equipment, waste disposal methods and location designation in the funeral industry.