Bongiovanni v. Commissioner: False Hopes for Cash Basis Taxpayers

In Bongiovanni v. Commissioner, the Second Circuit Court of Appeals applied a new interpretation of Section 357 to avoids taxing income recognized after the taxpayer transfers property to a corporation under a Section 351 exchange. However, this decision is ripe for review by the United States Supreme Court because it directly opposes Tax Court precedent and a similar Seventh Circuit case. This article recounts the background that led to Bongiovanni v. Commissioner, as well as examining cash versus accrual basis under Section 357(c) to decide whether the Bongiovanni decision actually comports with economic realities. In conclusion, the Comment concludes by recommending that Congress resolve the conflicting interpretations of Section 357

The Cladosporium fulvum-tomato interaction: elicitor proteins and their perception

The gene-for-gene concept postulates that for every dominant gene determining resistance in the host plant, there is a corresponding dominant gene conditioning avirulence in the pathogen. The simplest way to explain the biochemical basis of this concept is direct interaction between an elicitor protein, which is encoded by an avirulence ( Avr ) gene of the pathogen, and a receptor protein, which is encoded by the matching resistance ( R ) gene of the host. Perception of the elicitor protein by the host plant subsequently leads to the activation of defence responses, often including a hypersensitive response (HR).The research described in this thesis is focussed on the characterisation of elicitor proteins of the fungus Cladosporium fulvum and the analysis of their perception by resistant tomato plants. A striking feature of all elicitor proteins of C. fulvum is that their mature form contains an even number of cysteine residues. These cysteine residues are thought to be involved in disulfide bridges, which are essential for proper conformation and stability of the elicitors. Mutational analysis of elicitor proteins ECP1, ECP2 and ECP5, however, revealed that the role of (the even number) of cysteine residues is more complex than anticipated, as not all cysteine residues appeared to be critical for the HR-inducing activity of the elicitor proteins (Chapter 2).During colonisation of the apoplastic space of tomato leaves, C. fulvum secretes elicitor proteins into the apoplast. All Cf genes, mediating resistance to particular races of C. fulvum , are predicted to encode extracytoplasmic, membrane-anchored glycoproteins that contain many leucine-rich repeats (LRRs). LRR domains are thought to be involved in protein-protein interactions. The extracellular localisation of the LRR region of the Cf proteins is consistent with a direct, extracellular perception of the corresponding elicitor proteins. To validate this hypothesis, binding studies were performed between avirulence protein AVR9 and the matching resistance protein Cf-9. Although extensive studies were performed in a multidisciplinary collaboration to prove a direct interaction between the two proteins, no specific binding between AVR9 and Cf-9 could be detected (Chapter 3). This implies that the simplest interpretation of the gene-for-gene concept, involving direct interaction of a pathogen-derived elicitor with a matching resistance gene product, does not hold for the Avr9 / Cf-9 gene pair and that at least a third component is involved in the perception of AVR9 by Cf-9.Also for Avr2/Cf-2 -mediated resistance a third component, Rcr3, seems to be involved. To allow dissection of the biochemical mechanism of perception of avirulence protein AVR2, we set out to clone Avr2 (Chapter 4). Avr2 cDNA was cloned based on the specific HR-inducing activity of the encoded protein in Cf2 tomato plants. Like the other Avr genes of C. fulvum , Avr2 encodes a small, secreted protein with an even number of cysteine residues. Analysis of strains of C. fulvum that are virulent on Cf2 tomato lines revealed various mutations in the Avr2 ORF that all result in the production of a truncated AVR2 protein. Interestingly, an additional modification was discovered, involving the insertion of a LINE-like element (a retrotransposable element), Cfl1, in the Avr2 ORF. Cfl1 is the first LINE-like element identified in C. fulvum and provides the first example of loss of avirulence of a plant pathogen due to insertion of a retrotransposable element in an Avr gene. Analysis of two different rcr3-mutant Cf2 tomato plants revealed that their ability to respond to AVR2 with a HR correlates with their degree of resistance to AVR2-producing strains of C. fulvum . These data support a role for Rcr3 in the perception of AVR2 by Cf-2.Direct perception of elicitor proteins by R proteins has been the prevailing working hypothesis to explain the biochemical basis of the gene-for-gene concept for years. The results of the research that is described in this thesis, however, do not support this hypothesis. Also for most other gene-for-gene relationships studied so far, experimental evidence appears to be more consistent with indirect perception of an AVR protein by an R protein (Chapter 5). Indirect perception implies that, beside the AVR and the R protein, at least a third component is required to induce defence responses. For several gene-for-gene relationships the nature of the putative third component is known. Although each of these components are suggested to be involved in basal defence mechanisms, their nature appears to be diverse. Hence, we argue that, although some elicitors might be directly perceived by the matching R protein, for most gene-for-gene relationships elicitor perception will turn out to be more complex

The Chisholm firestorm: observed microstructure, precipitation and lightning activity of a pyro-cumulonimbus

International audienceA fire storm that occurred on 28 May 2001 and devastated the town of Chisholm, ~150 km north of Edmonton, Alberta, induced a violent fire-invigorated cumulonimbus cloud. This pyro-cumulonimbus (pyro-Cb) had overshooting tops of 2.5?3 km above the tropopause, and injected massive amounts of smoke into the lower stratosphere. Fortunately, this event occurred under good coverage of radar, rain gauge, lightning and satellite measurements, which allowed in-depth documentation of the event, and gave us an opportunity to study the cloud top morphology and microstructure, precipitation and cloud electrification of the pyro-Cb. The combination of heat and smoke created a cloud with extremely small drops, which ascended rapidly in violent updrafts. There appeared to be little freezing up to the homogeneous freezing isotherm level of ?38°C. A cloud with such small and short-lived highly supercooled drops is incapable of producing precipitation except for few large graupel and hail, which produced the observed radar echoes and charged the cloud with positive lightning. The small cloud drops froze homogeneously to equally small ice particles, for which there is no mechanism to aggregate into precipitation particles, and which hence remain in the anvil. The lack of significant precipitation implies that only a small fraction of the smoke is scavenged, so that most of it is exhausted through the anvil to the upper troposphere and lower stratosphere. Comparisons with other cases suggest that a pyro-Cb does not have to be as violent as the Chisholm case for precipitation to be strongly suppressed. However, this level of convective vigor is necessary to create the overshooting updraft that injects the smoke into the lower stratosphere

Structural optimization and biological evaluation of 2-substituted 5-hydroxyindole-3-carboxylates as potent inhibitors of human 5-lipoxygenase.

Pharmacological suppression of leukotriene biosynthesis by inhibitors of 5-lipoxygenase (5-LO) is a strategy to intervene with inflammatory and allergic disorders. We recently presented 2-amino-5-hydroxy-1H-indoles as efficient 5-LO inhibitors in cell-based and cell-free assays. Structural optimization led to novel benzo[g]indole-3-carboxylates exemplified by ethyl 2-(3-chlorobenzyl)-5- hydroxy-1H-benzo[g]indole-3-carboxylate (compound 11a), which inhibits 5-LO activity in human neutrophils and recombinant human 5-LO with IC50 values of 0.23 and 0.086 μM, respectively. Notably, 11a efficiently blocks 5-LO product formation in human whole blood assays (IC50 = 0.83-1.6 μM) and significantly prevented leukotriene B4 production in pleural exudates of carrageenan-treated rats, associated with reduced severity of pleurisy. Together, on the basis of their high potency against 5-LO and the marked efficacy in biological systems, these novel and straightforward benzo[g]indole-3-carboxylates may have potential as anti-inflammatory therapeutics

The Chisholm firestorm: observed microstructure, precipitation and lightning activity of a pyro-Cb

International audienceA fire storm that occured on 28 May 2001 devastated the town of Chisholm, ~150 km north of Edmonton, Alberta, induced a violent fire-invigorated cumulonimbus cloud. This pyro-cumulonimbus (pyro-Cb) had overshooting tops of 2.5?3 km above the tropopause, and injected massive amounts of smoke into the lower stratosphere. Fortunately, this event occurred under good coverage of radar, rain gauge, lightning and satellite measurements, which allowed in-depth documentation of the event. The combination of heat and smoke created a cloud with extremely small drops, which ascended rapidly in violent updrafts. There appeared to be little freezing up to the homogeneous freezing isotherm level of ?38°C. A cloud with such small and short-lived highly supercooled drops is incapable of producing precipitation except for few large graupel and hail, which produced the observed radar echoes and charged the cloud with positive lightning. The small cloud drops froze homogeneously to equally small ice particles, for which there is no mechanism to aggregate into precipitation particles that hence remain in the anvil. The small precipitation efficiency implies that only a small fraction of the smoke is scavenged, so that most of it is exhausted through the anvil to the upper troposphere and lower stratosphere. Comparisons with other cases suggest that a pyro-Cb does not have to be as violent as the Chisholm case to have strongly suppressed precipitation. However, this level of convective vigor is necessary to create the overshooting updraft that injects the smoke into the lower stratosphere

Narrative-driven alternative roads to achieve mid-century CO2 net neutrality in Europe

The tightened climate mitigation targets of the EU green deal raise an important question: Which strategy should be used to achieve carbon emissions net neutrality? This study explores stakeholder-designed narratives of the future energy system development within the deep decarbonization context. European carbon net-neutrality goals are put under test in a model comparison exercise using state of the art Energy-Environment-Economy (E3) models: ETM-UCL, PRIMES and REMIND. Results show that while achieving the transition to carbon neutrality by mid-century is feasible under quite different future energy systems, some robust commonalities emerge. Electrification of end use sectors combined with large-scale expansion of renewable energy is a no-regret decision for all strategies; Carbon Dioxide Removal (CDR) plays an important role for achieving net-neutral targets under all scenarios, but is most relevant when demand-side changes are limited; hydrogen and synthetic fuels can be a relevant mitigation option for mid-century mitigation in hard-to-abate sectors; energy efficiency can reduce the supply system strain. Finally, high carbon prices (300-900€/tCO2) are needed under all strategies in order to achieve carbon net neutrality in 2050

Reactions of (-)-sparteine with alkali metal HMDS complexes : conventional meets the unconventional

Conventional (-)-sparteine adducts of lithium and sodium 1,1,1,3,3,3-hexamethyldisilazide (HMDS) were prepared and characterised, along with an unexpected and unconventional hydroxyl-incorporated sodium sodiate, [(-)-sparteine·Na(-HMDS)Na·(-)-sparteine]+[Na4(-HMDS)4(OH)]--the complex anion of which is the first inverse crown ether anion

Modeling of biomass smoke injection into the lower stratosphere by a large forest fire (Part I): reference simulation

Wildland fires in boreal regions have the potential to initiate deep convection, so-called pyro-convection, due to their release of sensible heat. Under favorable atmospheric conditions, large fires can result in pyro-convection that transports the emissions into the upper troposphere and the lower stratosphere. Here, we present three-dimensional model simulations of the injection of fire emissions into the lower stratosphere by pyro-convection. These model simulations are constrained and evaluated with observations obtained from the Chisholm fire in Alberta, Canada, in 2001. The active tracer high resolution atmospheric model (ATHAM) is initialized with observations obtained by radiosonde. Information on the fire forcing is obtained from ground-based observations of the mass and moisture of the burned fuel. Based on radar observations, the pyro-convection reached an altitude of about 13 km, well above the tropopause, which was located at about 11.2 km. The model simulation yields a similarly strong convection with an overshoot of the convection above the tropopause. The main outflow from the pyro-convection occurs at about 10.6 km, but a significant fraction (about 8%) of the emitted mass of the smoke aerosol is transported above the tropopause. In contrast to regular convection, the region with maximum updraft velocity in the pyro-convection is located close to the surface above the fire. This results in high updraft velocities >10 m s^−1 at cloud base. The temperature anomaly in the plume decreases rapidly with height from values above 50 K at the fire to about 5 K at about 3000 m above the fire. While the sensible heat released from the fire is responsible for the initiation of convection in the model, the release of latent heat from condensation and freezing dominates the overall energy budget. Emissions of water vapor from the fire do not significantly contribute to the energy budget of the convection