1,818 research outputs found

    From Anecdote to Evidence: Assessing the Status and Condition of Arts Education at the State Level

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    Without solid evidence about the status and condition of arts education in the nation's public schools, it is difficult to make a convincing case for the arts. This research and policy brief draws on the experiences of five states -- Illinois, Kentucky, New Jersey, Rhode Island, and Washington -- as the basis for a discussion of various approaches and methodologies for conducting statewide arts education research

    Revenue Ruling 78-401: The Retained Control Test of Section 302(b)(1)

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    One of the questions remaining unanswered after United States v. Davis is whether loss of control over corporate acts requiring supermajority stockholder approval constitutes a meaningful reduction in a shareholder\u27s proportionate interest so as to qualify for sale or exchange treatment under section 302(b)(1). Recently, in Revenue Ruling 78-401, the Service ruled that such a limited loss of control does not qualify, contrary to two cases holding that it does. The author analyzes the rationale underlying the use of control to test for essential equivalency to a dividend and concludes that the test established in Revenue Ruling 78-401 is correct

    Revenue Ruling 78-401: The Retained Control Test of Section 302(b)(1)

    Get PDF
    One of the questions remaining unanswered after United States v. Davis is whether loss of control over corporate acts requiring supermajority stockholder approval constitutes a meaningful reduction in a shareholder\u27s proportionate interest so as to qualify for sale or exchange treatment under section 302(b)(1). Recently, in Revenue Ruling 78-401, the Service ruled that such a limited loss of control does not qualify, contrary to two cases holding that it does. The author analyzes the rationale underlying the use of control to test for essential equivalency to a dividend and concludes that the test established in Revenue Ruling 78-401 is correct

    The great debate: Truman\u27s decision to deploy American ground forces to Europe, 1950-1951

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    Following World War II the United States Government made world commitments which were no less than revolutionary. Sooner or later President Harry S. Truman had to come to a showdown with his critics, for the conservatives and pre-World War II isolationists never readily accepted America\u27s new position in world affairs. As frustration mounted, right wing elements of the Republican Party combined with a few dissident Democrats to challenge the Administration in its handling of foreign affairs. The fall of China followed a short time later by aggression in Korea solidified the Truman critics and opened what amounted to a major discussion of foreign policy goals and the means of achieving those ends. The debate attracted the attention of a growing Air Force lobby and, at the same time, lent itself to political gain for a party long absent from the White House. Like the various opinions expressed at the time, the implications were wide-ranging

    Securities

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    Transfers of Know-How under Section 351

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