Taxation - Internal Revenue Code - Waiver of Sovereign Immunity

The United States Supreme Court held that a nontaxpayer has standing to bring a tax refund action under the Internal Revenue Code and that the term taxpayer in the Internal Revenue Code is not limited to the party assessed a tax. United States v. Williams, 115 S. Ct. 1611 (1995)

Degradation of small simple and large complex lunar craters: Not a simple scale dependence

The crater record of a planetary surface unit is often analyzed by its cumulative size‐frequency distribution (CSFD). Measuring CSFDs involves traditional approaches, such as traditional crater counting (TCC) and buffered crater counting (BCC), as well as geometric corrections, such as nonsparseness correction (NSC) and buffered nonsparseness correction (BNSC). NSC and BNSC consider the effects of geometric crater obliteration on the CSFD. On the Moon, crater obliteration leads to two distinct states in which obtained CSFDs do not match the production CSFD—crater equilibrium and nonsparseness. Crater equilibrium occurs when each new impact erases a preexisting crater of the same size. It is clearly observed on lunar terrains dominated by small simple craters with steep‐sloped production CSFDs, such as Imbrian to Eratosthenian‐era mare units. Nonsparseness, on the other hand, is caused by the geometric overlap of preexisting craters by a new impact, which is also known as “cookie cutting.” Cookie cutting is most clearly observed on lunar terrains dominated by large craters with shallow‐sloped production CSFDs, such as the pre‐Nectarian lunar highlands. We use the Cratered Terrain Evolution Model (CTEM) to simulate the evolution of a pre‐Nectarian surface unit. The model was previously used to simulate the diffusion‐induced equilibrium for small craters of the lunar maria. We find that relative to their size, large craters contribute less to the diffusion of the surrounding landscape than small craters. Thus, a simple scale dependence cannot account for the per‐crater contribution to degradation by small simple and large complex craters

Inelastic and reactive scattering of hyperthermal atomic oxygen from amorphous carbon

The reaction of hyperthermal oxygen atoms with an amorphous carbon-13 surface was studied using a modified universal crossed molecular beams apparatus. Time-of-flight distributions of inelastically scattered O-atoms and reactively scattered CO-13 and CO2-13 were measured with a rotatable mass spectrometer detector. Two inelastic scattering channels were observed, corresponding to a direct inelastic process in which the scattered O-atoms retain 20 to 30 percent of their initial kinetic energy and to a trapping desorption process whereby O-atoms emerge from the surface at thermal velocities. Reactive scattering data imply the formation of two kinds of CO products, slow products whose translational energies are determined by the surface temperature and hyperthermal (Approx. 3 eV) products with translational energies comprising roughly 30 percent of the total available energy (E sub avl), where E sub avl is the sum of the collision energy and the reaction exothermicity. Angular data show that the hyperthermal CO is scattered preferentially in the specular direction. CO2 product was also observed, but at much lower intensities than CO and with only thermal velocities

Prejudice and effective anti-bullying intervention: Evidence from the bullying of "minorities"

The tradition of research into school bullying, and the development of anti-bullying intervention programmes in Norway, has had a significant influence upon similar efforts being made in other countries. However, recent evaluations of the effectiveness of school-based anti-bullying interventions have revealed mixed and most often modest levels of success. This in turn has led to suggestions being made in Norway that rather than to continue support for a direct approach to the issue of school bullying, making improvements in the "learning environment" should be prioritized; however, it is argued here that there is, as yet, no body of direct evidence to directly confirm that position. Instead, it is contended that research into school bullying has been limited to the conceptualization of bullying as being purely a sub-set of aggression, and that anti-bullying intervention has been, consequently, focused largely on purely behaviour management solutions. From recent studies on specific forms of bullying of minority groups (lesbian, gay and bisexual young people, ethnic minorities, people with disabilities or special educational needs and members of alternative sub-cultures), it appears that prejudice is at least influential on specific patterns of bullying behaviour, but has not received sufficient attention in either the conceptualization of bullying or the design of programmes to prevent and counter it. Hence, rather than scaling down direct anti-bullying intervention efforts, it is suggested that subsequent research and programme design could be re-focused in order to give a greater consideration to prejudice as an underlying factor. © 2014 The Editors of Nordic Psychology

An investigation of the degradation of Fluorinated Ethylene Propylene (FEP) copolymer thermal blanketing materials aboard LDEF in the laboratory

Samples of fluorinated ethylene propylene copolymer thermal blanketing material, recovered from the Long Duration Exposure Facility (LDEF), were investigated to determine the nature and the extent of degradation due to exposure to the low-Earth-orbit environment. Samples recovered from the ram-facing direction of LDEF, which received vacuum-ultraviolet (VUV) radiation and atomic-oxygen impingement, and samples from the trailing edge, which received almost exclusively VUV exposure, were investigated by scanning electron microscopy and atomic force microscopy. The most significant result of this investigation was found on samples that received only VUV exposure. These samples possessed a hard, embrittled surface layer that was absent from the atomic-oxygen exposed sample and from unexposed control samples. This surface layer is believed to be responsible for the 'synergistic' effect between VUV and atomic oxygen. Overall, the investigation revealed dramatically different morphologies for the two samples. The sample receiving both atomic-oxygen and VUV exposure was deeply eroded and had a characteristic 'rolling' surface morphology, while the sample that received only VUV exposure showed mild erosion and a surface morphology characterized by sharp high-frequency peaks. The morphologies observed in the LDEF samples, including the embrittled surface layer, were successfully duplicated in the laboratory

The impact of active stakeholder involvement on recruitment, retention and engagement of schools, children and their families in the cluster randomised controlled trial of the Healthy Lifestyles Programme (HeLP): a school-based intervention to prevent obesity

This is the final version of the article. Available from BioMed Central via the DOI in this record.BACKGROUND: Recruitment and retention of participants is crucial for statistical power and internal and external validity and participant engagement is essential for behaviour change. However, many school-based interventions focus on programme content rather than the building of supportive relationships with all participants and tend to employ specific standalone strategies, such as incentives, to improve retention. We believe that actively involving stakeholders in both intervention and trial design improves recruitment and retention and increases the chances of creating an effective intervention. METHODS: The Healthy Lifestyles Programme, HeLP (an obesity prevention programme for children 9-10 years old) was developed using intervention mapping and involved extensive stakeholder involvement in both the design of the trial and the intervention to ensure that: (i) delivery methods were suitably engaging, (ii) deliverers had the necessary skills and qualities to build relationships and (iii) the intervention dovetailed with the National Curriculum. HeLP was a year-long intervention consisting of 4 multi-component phases using a range of delivery methods. We recruited 1324 children from 32 schools from the South West of England to a cluster-randomised controlled trial to determine the effectiveness of HeLP in preventing obesity. The primary outcome was change in body mass index standard deviation score (BMI SDS) at 24 months post randomisation. Secondary outcomes included additional anthropometric and behavioural (physical activity and diet) measures at 18 and 24 months. RESULTS: Anthropometric and behavioural measures were taken in 99%, 96% and 94% of children at baseline, 18 and 24 months, respectively, with no differential follow up between the control and intervention groups at each time point. All children participated in the programme and 92% of children and 77% of parents across the socio-economic spectrum were considered to have actively engaged with HeLP. CONCLUSIONS: We attribute our excellent retention and engagement results to the high level of stakeholder involvement in both trial and intervention design, the building of relationships using appropriate personnel and creative delivery methods that are accessible to children and their families across the social spectrum. TRIAL REGISTRATION: International Standard Randomised Controlled Trials Register, ISRCTN15811706 . Registered on 1 May 2012.The UK National Institute for Health Research (NIHR) Public Health Research Programme (10/3010/01) funded all research activities for the HeLP RCT. The costs of the intervention were funded by the Peninsula College of Medicine and Dentistry

Polymer Translocation in Crowded Environments

We study the effect of the crowded nature of the cellular cytoplasm on the translocation of a polymer through a pore in a membrane. By systematically treating the entropic penalty due to crowding, we show that the translocation dynamics are significantly altered, leading to novel scaling behaviors of the translocation time in terms of chain length. We also observe new and qualitatively different translocation regimes depending upon the extent of crowding, transmembrane chemical potential asymmetry, and polymer length.Comment: 4 figure