TAXING DISTRIBUTIONS PURSUANT TO CORPORATE REORGANIZATIONS

Distributions implies that we are concerned with the tax problems of the stockholder rather than those of the corporation. And while one corporation may be the stockholder of another, my emphasis will be primarily upon stockholders who are individuals, including, of course, trusts and estates who are taxed as individuals

Cellular mappings on manifolds

Cellular mappings of a manifold onto itself possess many properties of homeomorphisms. In particular; for n ≠ M, a continuous function defined from a manifold onto itself is cellular if and only if it can be uniformly approximated by homeomorphisms. This thesis is a study of cellular mappings, spaces of cellular mappings and a class of mappings, called UV ∞maps which are a natural generalization of cellular mappings for spaces which are not manifolds. In Chapter one we prove that the space of cellular mappings from a manifold onto itself is a topological semi-group and that the space of all cellular mappings of Bn onto itself which are the identity on the boundary is locally contractible. The main theorem of Chapter two is that a mapping f of the n-sphere, n ≠ 4, onto itself is cellular if and only if f has a continuous extension which maps the interior of the n+1 ball homeomorphically onto itself. This theorem is a hither dimensional analogue of a result of Floyd and fort [11]. For higher dimensional manifolds with boundary, Mn, we show that if f mars the interior of M onto itself and the boundary of M onto itself and if f restricted to the interior is cellular, then f restricted to the boundary of M is also cellular. Chapter three is concerned with showing that under certain conditions cellular mappings can be replaced in a canonical manner with bounded cellular mappings that agree with the original mappings on a given set. Similar techniques have proven valuable in studying homeomorphisms and spaces of homeomorphisms. In Chapter four we introduce a new type of covering property possessed by many metric spaces and show that possession of this property by the space of cellular mappings of Bn onto itself would show that the space of cellular mappings of manifold onto itself is locally contractible. In Chapter five we show that if f:X Y, Y a metric space, is a UV-map, K a locally finite complex and h:K V is any continuous function, then for any E \u3e 0 there exists a mapping g:K X such that fg is E-homotopic to h

The Essence of Philosophy

Wilhelm Dilthey (1833-1911), the great German humanist, remained a towering figure in Europe long into the twentieth century. Published in 1954, this translation by Stephen A. Emery and William T. Emery was the first English translation of Dilthey's "Das Wesen der Philosophie" (1907) as well as his first work to be translated completely into English, making Dilthey accessible to scholars of the English-speaking world

Baroclinic Rossby waves as inferred from temperature fluctuations in the Eastern Pacific

Monthly mean values of temperature from both hydrographic and XBT casts are used to compute isotherm displacements at weather station November (30N, 140W) and at six 2-degree squares between Hawaii and the weather station. A composite spectrum computed from all the isotherms in the six 2-degree squares shows significantly higher potential energy in the frequency range below the theoretical cut-off frequency (corresponding period about five months) for baroclinic Rossby waves...

Automatic AVHRR image navigation software

This is the final report describing the work done on the project entitled Automatic AVHRR Image Navigation Software funded through NASA-Washington, award NAGW-3224, Account 153-7529. At the onset of this project, we had developed image navigation software capable of producing geo-registered images from AVHRR data. The registrations were highly accurate but required a priori knowledge of the spacecraft's axes alignment deviations, commonly known as attitude. The three angles needed to describe the attitude are called roll, pitch, and yaw, and are the components of the deviations in the along scan, along track and about center directions. The inclusion of the attitude corrections in the navigation software results in highly accurate georegistrations, however, the computation of the angles is very tedious and involves human interpretation for several steps. The technique also requires easily identifiable ground features which may not be available due to cloud cover or for ocean data. The current project was motivated by the need for a navigation system which was automatic and did not require human intervention or ground control points. The first step in creating such a system must be the ability to parameterize the spacecraft's attitude. The immediate goal of this project was to study the attitude fluctuations and determine if they displayed any systematic behavior which could be modeled or parameterized. We chose a period in 1991-1992 to study the attitude of the NOAA 11 spacecraft using data from the Tiros receiving station at the Colorado Center for Astrodynamic Research (CCAR) at the University of Colorado

A land-surface Testbed for EOSDIS

The main objective of the Testbed project was to deliver satellite images via the Internet to scientific and educational users free of charge. The main method of operations was to store satellite images on a low cost tape library system, visually browse the raw satellite data, access the raw data filed, navigate the imagery through 'C' programming and X-Windows interface software, and deliver the finished image to the end user over the Internet by means of file transfer protocol methods. The conclusion is that the distribution of satellite imagery by means of the Internet is feasible, and the archiving of large data sets can be accomplished with low cost storage systems allowing multiple users

A Critical Analysis of the EPAS Competencies and Practice Behaviors

This papers reviews the changes in the expectations regarding EPAS Competencies and Practice Behaviors since first presented by CSWE and how that has affected program development and outcome assessment. The language of the EPAS is critiqued from several perspectives, including Bloom\u27s Taxonomy, face validity, and exhaustiveness

Sea ice motions in the Central Arctic pack ice as inferred from AVHRR imagery

Synoptic observations of ice motion in the Arctic Basin are currently limited to those acquired by drifting buoys and, more recently, radar data from ERS-1. Buoys are not uniformly distributed throughout the Arctic, and SAR coverage is currently limited regionally and temporally due to the data volume, swath width, processing requirements, and power needs of the SAR. Additional ice-motion observations that can map ice responses simultaneously over large portions of the Arctic on daily to weekly time intervals are thus needed to augment the SAR and buoys data and to provide an intermediate-scale measure of ice drift suitable for climatological analyses and ice modeling. Principal objectives of this project were to: (1) demonstrate whether sufficient ice features and ice motion existed within the consolidated ice pack to permit motion tracking using AVHRR imagery; (2) determine the limits imposed on AVHRR mapping by cloud cover; and (3) test the applicability of AVHRR-derived motions in studies of ice-atmosphere interactions. Each of these main objectives was addressed. We conclude that AVHRR data, particularly when blended with other available observations, provide a valuable data set for studying sea ice processes. In a follow-on project, we are now extending this work to cover larger areas and to address science questions in more detail

A Review of the Literature on Adolescent Smoking and Cessation Programs

Over 4.5 million adolescents smoke cigarettes (Johnston, 2001; American Lung Association, 2003) half of all adolescents who become addicted to cigarettes will smoke for at least 20 years before they quit (Choi, Ahluwalia, Nazir, 2002), 80% of adult smokers began when they were adolescents (Abrantes et al., 2008), and an estimated 6.4 million children aged <18 years living today will die prematurely as adults because they began using tobacco during adolescence (American Lung Association, 2003; Centers for Disease Control and Prevention [CDC], 2006c). A majority of adolescents wants to quit tobacco with up to two-thirds reporting an attempt at quitting in 2007 (Abrantes et al., 2008). Smoking cessation programs for adolescents are not well studied and have not received the same amount of research that smoking cessation programs for adults have received (Sussman, Sun, Dent, 2006; Abrantes et al., 2008). This review of the literature on adolescent smoking and cessation programs provides a summary of what has been studied to date and what needs to be done in order to provide the best evidence-based smoking cessation programs for adolescents.Master of Public Healt