An Empirical Investigation of the Minority Interest and Marketability Discounts In Valuation of Closely Held Stock for Estate and Gift Tax Purposes

The discounts for lack of marketability and minority interest are crucial in reducing the value of transferred interests of closely held companies for estate and gift tax purposes. Because the current highest marginal estate and gift tax rate is 49%, there is a strong inducement for CPAs, Attorneys, Investment Bankers, Financial Planners, and others who value these transfers to accurately gauge the judicially allowed discounts for lack of marketability and minority interests in the valuation of closely held stock. This study examines the relationship between Tax Court determined values for lack of marketability and minority discounts to closely held stock from the compromise percentages. Compromise percentage is defined as the mean of the percentage presented by the adversarial parties, the taxpayer, and the IRS, in a judicial action. Additionally, this relationship is examined across industry classifications. The period investigated covers January 1, 1973 through December 31, 2002. Both regular and memorandum decisions by the Tax Court are analyzed over this thirty-year span. Chi-square analysis is used to determine that the Tax Court determined values are not significantly different than the compromise percentages. Furthermore, this finding does not vary across industries. Regression and chi-squared results are augmented with descriptive statistics

An Empirical Investigation of the Minority Interest and Marketability Discounts In Valuation of Closely Held Stock for Estate and Gift Tax Purposes

The discounts for lack of marketability and minority interest are crucial in reducing the value of transferred interests of closely held companies for estate and gift tax purposes. Because the current highest marginal estate and gift tax rate is 49%, there is a strong inducement for CPAs, Attorneys, Investment Bankers, Financial Planners, and others who value these transfers to accurately gauge the judicially allowed discounts for lack of marketability and minority interests in the valuation of closely held stock. This study examines the relationship between Tax Court determined values for lack of marketability and minority discounts to closely held stock from the compromise percentages. Compromise percentage is defined as the mean of the percentage presented by the adversarial parties, the taxpayer, and the IRS, in a judicial action. Additionally, this relationship is examined across industry classifications. The period investigated covers January 1, 1973 through December 31, 2002. Both regular and memorandum decisions by the Tax Court are analyzed over this thirty-year span. Chi-square analysis is used to determine that the Tax Court determined values are not significantly different than the compromise percentages. Furthermore, this finding does not vary across industries. Regression and chi-squared results are augmented with descriptive statistics

A production-adapted, multi-auxotrophic, CHO cell line for reducing monoclonal and bispecific antibody cell line development timelines

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Motivated knowledge acquisition: implicit self-theories and the preference for knowledge breadth or depth

Implicit self-theories posit that individuals ascribe to one of two beliefs regarding the self: an incremental theory motivated by learning goals and an entity theory motivated by performance goals. This work proposes that these theories—and their underlying motivations—reflect individuals’ preferences for different knowledge types. Specifically, we propose that incremental theorists prefer knowledge that expands their understanding of diverse experiences within a category (i.e., knowledge breadth), whereas entity theorists prefer knowledge that refines their understanding of a preferred experience within a category (i.e., knowledge depth). Five studies show the effect of implicit self-theories on individuals’ preferences for knowledge breadth and depth and the role of learning and performance goals in motivating these knowledge preferences. We address alternative explanations related to general openness, risk-seeking, and perceived quality differences, and we demonstrate the role of negative feedback in reversing these knowledge preferences

Any health care reform must allow continuation of robust Medicaid Buy-In programs for working people with disabilities

National health care reform must meet the unique health care needs of people with disabilities. However, obtaining health care coverage for a person with disabilities can be challenging in an employer-based health insurance environment. The final healthcare reform act must ensure that working people with disabilities retain the options they currently have to participate; any legislation should embed Medicaid Buy-in cocerage and provide states the flexibility they need to support individuals with disabilities in employmen

Two nonrecombining sympatric forms of the human malaria parasite Plasmodium ovale occur globally.

BACKGROUND: Malaria in humans is caused by apicomplexan parasites belonging to 5 species of the genus Plasmodium. Infections with Plasmodium ovale are widely distributed but rarely investigated, and the resulting burden of disease is not known. Dimorphism in defined genes has led to P. ovale parasites being divided into classic and variant types. We hypothesized that these dimorphs represent distinct parasite species. METHODS: Multilocus sequence analysis of 6 genetic characters was carried out among 55 isolates from 12 African and 3 Asia-Pacific countries. RESULTS: Each genetic character displayed complete dimorphism and segregated perfectly between the 2 types. Both types were identified in samples from Ghana, Nigeria, São Tomé, Sierra Leone, and Uganda and have been described previously in Myanmar. Splitting of the 2 lineages is estimated to have occurred between 1.0 and 3.5 million years ago in hominid hosts. CONCLUSIONS: We propose that P. ovale comprises 2 nonrecombining species that are sympatric in Africa and Asia. We speculate on possible scenarios that could have led to this speciation. Furthermore, the relatively high frequency of imported cases of symptomatic P. ovale infection in the United Kingdom suggests that the morbidity caused by ovale malaria has been underestimated

Arthroscopic rotator cuff repair with a fibrin scaffold containing growth factors and autologous progenitor cells derived from humeral cBMA improves clinical outcomes in high risk patients

PURPOSE: To report the clinical outcomes after biologically augmented rotator cuff repair (RCR) with a fibrin scaffold derived from autologous whole blood and supplemented with concentrated bone marrow aspirate (cBMA) harvested at the proximal humerus. METHODS: Patients who underwent arthroscopic RCR with biologic augmentation using a fibrin clot scaffold (“Mega- Clot”) containing progenitor cells and growth factors from proximal humerus BMA and autologous whole blood between April 2015 and January 2018 were prospectively followed. Only high-risk patients in primary and revision cases that possessed relevant comorbidities or physically demanding occupation were included. Minimum follow-up for inclusion was 1 year. The visual analog score for pain (VAS), American Shoulder and Elbow Surgeons (ASES), Simple Shoulder Test (SST), Single Assessment Numerical Evaluation (SANE), and Constant-Murley scores were collected preoperatively and at final follow-up. In vitro analyses of the cBMA and fibrin clot using nucleated cell count, colony forming units, and live/dead assays were used to quantify the substrates. RESULTS: Thirteen patients (56.9 ± 7.7 years) were included. The mean follow-up was 26.9 ± 17.7 months (n = 13). There were significant improvements in all outcome scores from the preoperative to the postoperative state: VAS (5.6 ± 2.5 to 3.1 ± 3.2; P < .001), ASES (42.0 ± 17.1 to 65.5 ± 30.6; P < .001), SST (3.2 ± 2.8 to 6.5 ± 4.7; P = .002), SANE (11.5 ± 15.6 to 50.3 ± 36.5; P < .001), and Constant-Murley (38.9 ± 17.5 to 58.1 ± 26.3; P < .001). Six patients (46%) had retears on postoperative MRI, despite all having improvements in pain and function except one. All failures were chronic rotator cuff tears, and all were revision cases except one (1.6 ± 0.5 previous RCRs). The representative sample of harvested cBMA showed an average of 28.5 ± 9.1 × 10(6) nucleated cells per mL. CONCLUSIONS: Arthroscopic rotator cuff repairs that are biologically augmented with a fibrin scaffold containing growth factors and autologous progenitor cells derived from autologous whole blood and humeral cBMA can improve clinical outcomes in primary, as well as revision cases in high-risk patients. However, the incidence of retears remains a concern in this population, demanding further improvements in biologic augmentation. LEVEL OF EVIDENCE: IV, therapeutic case series

Urinary p75(ECD): A prognostic, disease progression, and pharmacodynamic biomarker in ALS.

OBJECTIVE: To evaluate urinary neurotrophin receptor p75 extracellular domain (p75(ECD)) levels as disease progression and prognostic biomarkers in amyotrophic lateral sclerosis (ALS). METHODS: The population in this study comprised 45 healthy controls and 54 people with ALS, 31 of whom were sampled longitudinally. Urinary p75(ECD) was measured using an enzyme-linked immunoassay and validation included intra-assay and inter-assay coefficients of variation, effect of circadian rhythm, and stability over time at room temperature, 4°C, and repeated freeze-thaw cycles. Longitudinal changes in urinary p75(ECD) were examined by mixed model analysis, and the prognostic value of baseline p75(ECD) was explored by survival analysis. RESULTS: Confirming our previous findings, p75(ECD) was higher in patients with ALS (5.6 ± 2.2 ng/mg creatinine) compared to controls (3.6 ± 1.4 ng/mg creatinine, p < 0.0001). Assay reproducibility was high, with p75(ECD) showing stability across repeated freeze-thaw cycles, at room temperature and 4°C for 2 days, and no diurnal variation. Urinary p75(ECD) correlated with the revised ALS Functional Rating Scale at first evaluation (r = -0.44, p = 0.008) and across all study visits (r = -0.36, p < 0.0001). p75(ECD) also increased as disease progressed at an average rate of 0.19 ng/mg creatinine per month (p < 0.0001). In multivariate prognostic analysis, bulbar onset (hazard ratio [HR] 3.0, p = 0.0035), rate of disease progression from onset to baseline (HR 4.4, p < 0.0001), and baseline p75(ECD) (HR 1.3, p = 0.0004) were predictors of survival. CONCLUSIONS: The assay for urinary p75(ECD) is analytically robust and shows promise as an ALS biomarker with prognostic, disease progression, and potential pharmacodynamic application. Baseline urinary p75(ECD) provides prognostic information and is currently the only biological fluid-based biomarker of disease progression