Below Market Loans: From Abuse to Misuses – A Sports Illustration

Below market loans have been traditionally used as substitutes for gifts, salaries, and dividends for the primary purpose of tax avoidance in the transfer of wealth. The Supreme Court\u27s opinion in Dickman v. Commissioner subjected both demand and term loans in an intrafamilial setting to the federal gift tax. Congress, while subjecting all below market loans to either income or gift tax, applied different valuation formulas to term and demand loans and, in so doing, favored the use of demand loans as a salary substitute. This Article analyzes the current status of below market loans by examining their use in a typical business setting - the professional sports industry. Dean Closius and Professor Chapman argue that Congress should establish tax neutrality as between term and demand loans. This result can be achieved by providing an income tax for demand loans, by ascribing the borrower\u27s below market benefit to the lender, or by statutorily imputing a term of years to all demand loans

Late Neogene exhumation patterns in Taranaki Basin (New Zealand): evidence from offset porosity-depth trends

Journal ArticleTaranaki Basin, New Zealand, is located adjacent to the Australian-Pacific Plate boundary where the tectonic regime changes from dominantly subduction-related to the north to transpression-related along the Alpine Fault to the south. During the Neogene, burial and exhumation varied extensively, in both time and space, in response to subsidence and uplift along this evolving plate boundary zone

Exhumation of the central Wasatch Mountains, Utah: 1, Patterns and timing of exhumation deduced from low-temperature thermochronology data

Journal ArticleThe Wasatch Mountains are often cited as an example of normal fault growth and footwall flexure. They represent a tilted footwall at the edge of the Basin and Range extensional province, a major rift basin. Thus understanding the detailed spatial and elevation changes in coupled thermochronometer data, and how these changes can be interpreted, may aid in the analysis of thermochronometer data from other extensional regions around the world

TOLERANCE INTERVALS FOR GENE FLOW RATES FROM TRANSGENIC TO NON-TRANSGENIC WHEAT AND CORN USING A LOGISTIC REGRESSION MODEL WITH RANDOM LOCATION EFFECTS

Crop scientists and government regulators are interested in mediating pollen flow from transgenic crops to other crops and weed species. To this end, a multi-year, multilocation series of experiments was conducted in eastern Colorado by the Department of Soil and Crop Sciences at Colorado State University. These experiments were done to estimate the distance required between plots of transgenic corn and wheat and plots of the respective non-transgenic crop to obtain at most a regulated limit of cross-pollination. The experiments involved planting a rectangle of transgenic crop in the middle of a non-transgenic field and measuring the proportion of cross-pollinated crop at various distances along transects radiating in multiple directions. Gene flow to the non-transgenic crop was evaluated in wheat using herbicide tolerance and in corn using kernel color. An initial Generalized Linear Mixed Model with binomial response and logit link was estimated with independent variables: a square root transformation of distance, an additional covariate, and a random location effect. For corn, the additional covariate was transect orientation; for wheat, it was the relative heading time of the recipient variety. An enhanced model that included additional sources of variation was also examined. The analysis for both of these assumed models addresses two problems: 1) an Upper Tolerance Limit on the binomial probability of cross-pollination, which includes 100c% of the locations with 100d% confidence, at set values of the independent variables; and 2) an Upper Tolerance Limit on the distance at which 100c% of the locations will have binomial probability of cross-pollination less than a specified value, with 100d% confidence, at set values of the other independent variables. The problems are addressed using Frequentist and Bayesian methods

Child Care Provider Survival Analysis

The aggregate ability of child care providers to meet local demand for child care is linked to employment rates in many sectors of the economy. Amid growing concern regarding child care provider sustainability due to the COVID-19 pandemic, state and local governments have received large amounts of new funding to better support provider stability. In response to this new funding aimed at bolstering the child care market in Florida, this study was devised as an exploratory investigation into features of child care providers that lead to business longevity. In this study we used optimal survival trees, a machine learning technique designed to better understand which providers are expected to remain operational for longer periods of time, supporting stabilization of the child care market. This tree-based survival analysis detects and describes complex interactions between provider characteristics that lead to differences in expected business survival rates. Results show that small providers who are religiously affiliated, and all providers who are serving children in Florida's universal Prekindergarten program and/or children using child care subsidy, are likely to have the longest expected survival rates.Comment: 20 pages, 2 figure

Interactions between ecological factors in the developmental environment modulate pupal and adult traits in a polyphagous fly

Funding Information Macquarie University. Grant Number: 40310006 Horticulture Innovation Australia. Grant Number: HG14033Peer reviewedPublisher PD

Exhumation of the central Wasatch Mountains, Utah: 1. Patterns and timing of exhumation deduced from low‐temperature thermochronology data

Peer Reviewedhttp://deepblue.lib.umich.edu/bitstream/2027.42/94941/1/jgrb13374.pd

Commensal microbiota modulates larval foraging behaviour, development rate and pupal production in Bactrocera tryoni

Project Raising Q-fly Sterile Insect Technique to World Standard (HG14033) is funded by the Hort Frontiers Fruit Fly Fund, part of the Hort Frontiers strategic partnership initiative developed by Hort Innovation, with co-investment from Macquarie University and contributions from the Australian Government. BN is supported by an international Research Training Program (iRTP) scholarship from Macquarie University (NSW, Australia).Peer reviewedPublisher PD