Note and Comment

Special Assessments Upon Cemetaries - Though the power to tax cemeteries would seem to be\u27entirely clear, very commonly land devoted to such purpose is declared by constitution or statute to be exempt. See CooLY, TAxATION, (3rd ed.) 354. So also in the case of special assessments such land, in the absence of a clear exemption, is liable thereto. Bloomington Cemetery Assoc. v. People, i39 IIl. 16, 28 N. E. io76; Mullins v. Cemetery Assoc., 239 Mo. 681, i44 S. W. iog; Buffalo City Cemetery v. Buffalo, 46 N. Y. 5o3; Lima v. Lima Cemetery Assoc., 42 Oh. St. 128, 5! Am. Rep. 8ag. It may be suggested, in view of the theory upon which special assessments go; that the owner of the land gets back the amount assessed in benefits from an enhanced value of the property, land dedicated to cemetery purposes perpetually would not be subject to such assessments. This contention wa urged in Garden Cemetery Corporation v. Baker, 218 Mass. 339, 105 N. E. io7o (x9r4), and under the facts there presented was rejected, the court distinguishing Mount Auburn Cemetery v. Cambridge, i5o Mass. 12. Where all the lots are sold and used for burial and under the law the company cannot divert the land to other uses, perhaps the argument might be difficult to meet. Exemption from special assessment, then, in general, it would seem, must be found, if at all, in some provision or provisions of the conititution, statutes, or charter, or in some inherent difficulty in the collection of the assessments

Note and Comment

Simplification of Judicial Procedure in Federal Courts - In 1914 the Judiciary Committee of the House of Representatives unanimously reported favorably upon a bill (H. R. 133) authorizing the Supreme Court of the United States to prescribe by rule the forms, kind and character of the entire pleading, practice and procedure to be used in all actions and proceedings at law in the federal courts, with a view to their simplification, which rules should, when promulgated, take precedence of any law in conflict therewith. On January 2, 1917, a similar bill (S. 4551) was favorably reported from the Senate Judiciary Committee by a distinguished graduate of this Law School, Senator SUTHELAND. The concurrence of the Judiciary Committees of the two houses of Congress gives promise of an early enactment of this legislation

Note and Comment

The Appam Case - On March 6 last the Supreme Court handed down a unanimous decision in the appeals taken in the libel suits filed against the Appam and cargo in the District Court of the United States for the Eastern District of Virginia, affirming the decree of. restitution entered by that court

Note and Comment

Special Assessments Upon Cemetaries - Though the power to tax cemeteries would seem to be\u27entirely clear, very commonly land devoted to such purpose is declared by constitution or statute to be exempt. See CooLY, TAxATION, (3rd ed.) 354. So also in the case of special assessments such land, in the absence of a clear exemption, is liable thereto. Bloomington Cemetery Assoc. v. People, i39 IIl. 16, 28 N. E. io76; Mullins v. Cemetery Assoc., 239 Mo. 681, i44 S. W. iog; Buffalo City Cemetery v. Buffalo, 46 N. Y. 5o3; Lima v. Lima Cemetery Assoc., 42 Oh. St. 128, 5! Am. Rep. 8ag. It may be suggested, in view of the theory upon which special assessments go; that the owner of the land gets back the amount assessed in benefits from an enhanced value of the property, land dedicated to cemetery purposes perpetually would not be subject to such assessments. This contention wa urged in Garden Cemetery Corporation v. Baker, 218 Mass. 339, 105 N. E. io7o (x9r4), and under the facts there presented was rejected, the court distinguishing Mount Auburn Cemetery v. Cambridge, i5o Mass. 12. Where all the lots are sold and used for burial and under the law the company cannot divert the land to other uses, perhaps the argument might be difficult to meet. Exemption from special assessment, then, in general, it would seem, must be found, if at all, in some provision or provisions of the conititution, statutes, or charter, or in some inherent difficulty in the collection of the assessments

Note and Comment

The Appam Case - On March 6 last the Supreme Court handed down a unanimous decision in the appeals taken in the libel suits filed against the Appam and cargo in the District Court of the United States for the Eastern District of Virginia, affirming the decree of. restitution entered by that court

Rare predicted loss-of-function variants of type I IFN immunity genes are associated with life-threatening COVID-19

BackgroundWe previously reported that impaired type I IFN activity, due to inborn errors of TLR3- and TLR7-dependent type I interferon (IFN) immunity or to autoantibodies against type I IFN, account for 15-20% of cases of life-threatening COVID-19 in unvaccinated patients. Therefore, the determinants of life-threatening COVID-19 remain to be identified in similar to 80% of cases.MethodsWe report here a genome-wide rare variant burden association analysis in 3269 unvaccinated patients with life-threatening COVID-19, and 1373 unvaccinated SARS-CoV-2-infected individuals without pneumonia. Among the 928 patients tested for autoantibodies against type I IFN, a quarter (234) were positive and were excluded.ResultsNo gene reached genome-wide significance. Under a recessive model, the most significant gene with at-risk variants was TLR7, with an OR of 27.68 (95%CI 1.5-528.7, P=1.1x10(-4)) for biochemically loss-of-function (bLOF) variants. We replicated the enrichment in rare predicted LOF (pLOF) variants at 13 influenza susceptibility loci involved in TLR3-dependent type I IFN immunity (OR=3.70[95%CI 1.3-8.2], P=2.1x10(-4)). This enrichment was further strengthened by (1) adding the recently reported TYK2 and TLR7 COVID-19 loci, particularly under a recessive model (OR=19.65[95%CI 2.1-2635.4], P=3.4x10(-3)), and (2) considering as pLOF branchpoint variants with potentially strong impacts on splicing among the 15 loci (OR=4.40[9%CI 2.3-8.4], P=7.7x10(-8)). Finally, the patients with pLOF/bLOF variants at these 15 loci were significantly younger (mean age [SD]=43.3 [20.3] years) than the other patients (56.0 [17.3] years; P=1.68x10(-5)).ConclusionsRare variants of TLR3- and TLR7-dependent type I IFN immunity genes can underlie life-threatening COVID-19, particularly with recessive inheritance, in patients under 60 years old