A Giant Leap for Fairer Tax or Blind Compromise with Public Opinion? : A Review on the New Case Law on Substance-over-Form by the Supreme Court of Korea

This Article discusses recent developments pertaining to the substance-over-form principle in Korean tax law, which is sometimes regarded as a general anti-avoidance doctrine. In particular, this Article focuses on a recent judgment by the Supreme Court of Korea (the SC). After reviewing the relevant facts, the SCs holding, and its dissenting and supplementing opinions, this Article points out that this new case law is clearly a departure from the SCs old case law. This Article attempts to identify those theoretical factors and social incidents that influenced this radical change of direction. It is argued that this change in case law has to do with some real cases where sophisticated tax avoidance schemes were involved, but the tax authorities had difficulty in striking them down. Hostile public sentiment against these taxpayers led the legislature to enact statutory anti-avoidance rules of a general nature, and the administration to challenge the avoidance schemes employed by the taxpayers. In brief, it is argued that the new case law should be understood in conjunction with all those social incidents and their aftermath. However, whether this change can also be supported from legal perspectives is yet a difficult question to answer, and should be subject to further discussions.This Article is funded by the Seoul National University Law Foundation in 2013

Modeling and Analysis of Mobility Management in Mobile Communication Networks

Many strategies have been proposed to reduce the mobility management cost in mobile communication networks. This paper studies the zone-based registration methods that have been adopted by most mobile communication networks. We focus on two special zone-based registration methods, called two-zone registration (2Z) and two-zone registration with implicit registration by outgoing calls (2Zi). We provide a new mathematical model to analyze the exact performance of 2Z and 2Zi. We also present various numerical results, to compare the performance of 2Zi with those of 2Z and one-zone registration (1Z), and show that 2Zi is superior to 2Z as well as 1Z in most cases

Circulating levels of DNA-histone complex and dsDNA are independent prognostic factors of disseminated intravascular coagulation

AbstractIntroductionNeutrophils can be induced to release DNA combined with histones. The resulting neutrophil extracellular trap (NET) provides a scaffold for growing hemostatic plug. Therefore, the NET formation may be inevitable in clinical conditions that are characterized by formation of vascular thrombi. Thus far, there have been no reports on the clinical significance of NET in disseminated intravascular coagulation (DIC). Therefore, we investigated circulating levels of NET in DIC and analyzed their potential values to assess coagulation severity and predict clinical outcome.MethodsThe plasma levels of DNA-histone complexes and double-stranded DNA (dsDNA), considered to be in vivo markers of NET, were measured in 199 patients suspected of having DIC and 20 healthy controls.ResultThe circulating levels of DNA-histone complexes and dsDNA were significantly elevated in overt-DIC. The increased levels of these two markers correlated with the severity of coagulopathy including DIC score and D-dimer. Multivariable Cox regression analysis, adjusted for the conventional DIC markers, revealed that elevated DNA-histone complexes and dsDNA are poor independent prognostic markers.ConclusionThe circulating levels of NET release reflect the coagulation activation and adverse clinical outcomes in patients with DIC, thereby providing potential clinical relevance for mortality prediction in DIC

Human dopamine receptor nanovesicles for gate-potential modulators in high-performance field-effect transistor biosensors

The development of molecular detection that allows rapid responses with high sensitivity and selectivity remains challenging. Herein, we demonstrate the strategy of novel bio-nanotechnology to successfully fabricate high-performance dopamine (DA) biosensor using DA Receptor-containing uniform-particle-shaped Nanovesicles-immobilized Carboxylated poly(3,4-ethylenedioxythiophene) (CPEDOT) NTs (DRNCNs). DA molecules are commonly associated with serious diseases, such as Parkinson's and Alzheimer's diseases. For the first time, nanovesicles containing a human DA receptor D1 (hDRD1) were successfully constructed from HEK-293 cells, stably expressing hDRD1. The nanovesicles containing hDRD1 as gate-potential modulator on the conducting polymer (CP) nanomaterial transistors provided high-performance responses to DA molecule owing to their uniform, monodispersive morphologies and outstanding discrimination ability. Specifically, the DRNCNs were integrated into a liquid-ion gated field-effect transistor (FET) system via immobilization and attachment processes, leading to high sensitivity and excellent selectivity toward DA in liquid state. Unprecedentedly, the minimum detectable level (MDL) from the field-induced DA responses was as low as 10 pM in real- time, which is 10 times more sensitive than that of previously reported CP based-DA biosensors. Moreover, the FET-type DRNCN biosensor had a rapid response time (<1 s) and showed excellent selectivity in human serum

Thermoelectric properties of nanoporous three-dimensional graphene networks

We propose three dimensional-graphene nanonetworks (3D-GN) with pores in the range of 10 similar to 20 nm as a potential candidate for thermoelectric materials. The 3D-GN has a low thermal conductivity of 0.90 W/mK @773 K and a maximum electrical conductivity of 6660 S/m @773 K. Our results suggest a straightforward way to individually control two interdependent parameters, sigma and kappa, in the nanoporous graphene structures to ultimately improve the figure of merit value.open

PPM1A Controls Diabetic Gene Programming through Directly Dephosphorylating PPAR?? at Ser273

Peroxisome proliferator-activated receptor gamma (PPAR gamma) is a master regulator of adipose tissue biology. In obesity, phosphorylation of PPAR gamma at Ser273 (pSer273) by cyclin-dependent kinase 5 (CDK5)/extracellular signal-regulated kinase (ERK) orchestrates diabetic gene reprogramming via dysregulation of specific gene expression. Although many recent studies have focused on the development of non-classical agonist drugs that inhibit the phosphorylation of PPAR gamma at Ser273, the molecular mechanism of PPAR gamma dephosphorylation at Ser273 is not well characterized. Here, we report that protein phosphatase Mg2+/Mn2+-dependent 1A (PPM1A) is a novel PPAR gamma phosphatase that directly dephosphorylates Ser273 and restores diabetic gene expression which is dysregulated by pSer273. The expression of PPM1A significantly decreases in two models of insulin resistance: diet-induced obese (DIO) mice and db/db mice, in which it negatively correlates with pSer273. Transcriptomic analysis using microarray and genotype-tissue expression (GTEx) data in humans shows positive correlations between PPM1A and most of the genes that are dysregulated by pSer273. These findings suggest that PPM1A dephosphorylates PPAR gamma at Ser273 and represents a potential target for the treatment of obesity-linked metabolic disorders

‘Evidence of an auxin signal pathway, microRNA167-ARF8-GH3, and its response to exogenous auxin in cultured rice cells’

MicroRNA167 (miR167) was shown to cleave auxin responsive factor 8 (ARF8) mRNA in cultured rice cells. MiR167 level was found to be controlled by the presence of auxin in the growth medium. When cells grew in auxin-free medium, miR167 level decreased, resulting in an increase in the level of ARF8 mRNA. Cells growing in the normal growth medium containing auxin showed a reversed trend. It was also shown that expression of OsGH3-2, an rice IAA-conjugating enzyme, was positively regulated by ARF8. Delivery of synthesized miR167 into cells led to decrease of both ARF8 mRNA and OsGH3-2 mRNA. This study provides an evidence in which the exogeneous auxin signal is transduced to OsGH3-2 through miR167 and ARF8 in sequence. This proposed auxin signal transduction pathway, auxin-miR167-ARF8-OsGH3-2, could be, in conjunction with the other microRNA-mediated auxin signals, an important one for responding to exogeneous auxin and for determining the cellular free auxin level which guides appropriate auxin responses