PATENT ROYALTIES AS CAPITAL GAINS UNDER I.R.C., SECTION 117(a)

With the incidence of high personal surtax rates, a patentee is ordinarily interested in deriving the greatest monetary return after taxes, measured in proportion to the extent of use over what he expects to be the increasingly productive life of the intangible right evidenced by his patent, without surrendering his option to reclaim the patent in event of insolvency or lack of diligence on the part of the person to whom he transfers the patent for exploitation. Although ideal for these purposes, the favorable capital gain status under section 117(a) of the Internal Revenue Code, requiring recognition of only fifty per cent of gains resulting in any one year from· the sale or exchange of property held over six months, is not only difficult for such a patent owner to achieve, but expensive to maintain, in view of the Treasury\u27s persistent efforts to have the courts overrule, or at least narrowly limit application of, the Edward C. Myers case, which is the leading authority relied upon by patentees seeking capital gain rather than ordinary income treatment of proceeds from transfers with price payable in installments measured by the transferee exploiter\u27s production, sale or use under a patent

On the Theory of the Virial Development of the Equation of State of Monoatomic Gases

The problem of the condensation of a gas is intimately related to the asymptotic behavior of the virial coefficients, Bm, as m→∞. The problem of the evaluation of the virial coefficients may be divided into two distinctly different ones. The first of these, which is purely combinatorial in nature and is independent of the intermolecular force law, is that of determining the number of a certain type of connected graphs of l points and k lines which are called ``stars.'' This problem is solved by means of generating functions, with the result that the total number of such stars is asymptotically equal to(12l(l−1)k),for almost all k. Arguments are also presented which indicate that the total number of topologically different stars is1l!(12l(l−1)k).With these results the combinatorial problem is essentially solved.The second problem is that of evaluating certain integrals of functions which depend on the intermolecular potential. This problem is not so near to a solution. For a purely repulsive force, asymptotic expressions are obtained for k=l, and k=l+1. The partial contributions to the virial coefficient in these two cases are:(−1)l⋅53(52π)12(2b)l−1(l−1)l5∕2,and(−1)l2⋅5324π3(2b)l−1,respectively. Results for some simple one‐dimensional rigid lines are also given.Peer Reviewedhttp://deepblue.lib.umich.edu/bitstream/2027.42/69794/2/JCPSA6-21-11-2056-1.pd

On the Notion of Pressure in a Canonical Ensemble

Recently a controversy has arisen between J. De Boer and H. S. Green concerning the notion of pressure in a canonical ensemble. According to Green, only classically is the pressure as derived from the partition function equal to that obtained from the virial theorem, while at low temperatures, at which quantum effects become important, there will be considerable deviations between the two. De Boer attempts to prove that the two pressures are actually identical. We have come to the same conclusion, and shall show this in several ways; first, by considering a simple example (Section 2), and then in general using the energy representation (Section 3). We believe that the discrepancy between the two pressures which Green has found is in fact due to improper handling of the effect of the wall of the vessel in which the particles are contained. Finally, we are of the opinion that Green's criticism of De Boer's calculation is not justified, and in the last section arguments are given to show that the traces of all commutators of interest in quantum statistical mechanics are zero.Peer Reviewedhttp://deepblue.lib.umich.edu/bitstream/2027.42/69356/2/JCPSA6-18-8-1066-1.pd

An overview of the Salish Sea Marine Survival Project: U.S.-Canada integration

The Salish Sea Marine Survival Project (Project) is a multi-year transboundary effort to determine the primary factors affecting juvenile salmon and steelhead survival in the Salish Sea. The Project, coordinated by nonprofits Long Live the Kings (U.S.) and the Pacific Salmon Foundation (Canada), brings together multidisciplinary expertise from over 20 Federal and State agencies, Tribes, academia and nonprofit organizations on both sides of the U.S.-Canada border. Through the development of a comprehensive, ecosystem-based research framework; coordinated data collection and standardization; and improved information sharing, the Project will help managers better understand the critical relationship between salmon and the Salish Sea. This transboundary initiative began in 2012 and will last seven years. Foundational reports include the Pacific Salmon Foundation’s Strait of Georgia Chinook and Coho Proposal (2009) and subsequently the Hypotheses and Preliminary Research Recommendations for Puget Sound (2012). In November 2012, a workshop with 90 participants was held to receive feedback from the broader scientific community regarding the critical elements of a US-Canada research program. The foundational and workshop summary reports are available at the Project web site (www.marinesurvivalproject.org). Science teams are now using this information to develop and implement the necessary research. We will present an overview of the Salish Sea Marine Survival Project, describing its history, leading hypotheses for poor survival, current status in research development and implementation, and how this work will contribute to Salish Sea sustainable resource management and recovery efforts. We will highlight the multi-disciplinary, collaborative nature of this project and the role of non-governmental organizations in aiding this large-scale initiative

Interior Design Curriculum Evaluations by Graduates of the Program

There are many different, often conflicting, conceptions of what is meant by the term "curriculum." For some, it is a loose term encompassing the range of content or a course of study; for others, it is the singular textbook to which the class is assigned. The author believes in "curriculum" as that planned set of identified educational goals and learning experiences that are organized in a manner to facilitate growth in the learner. In the presentation of a successful interior design program, the importance of the teacher, in accompanying the curriculum for the student, is accepted as a major component to be built into all curriculum development efforts. The teacher is, in the vast majority of cases, the "curriculum gatekeeper." Without adequate attention to the teacher's day to day role, the entire curriculum may founder.Housing, Design, and Consumer Resource

Attitudes of General Practitioner Registrars and Their Trainers Toward Obesity Prevention in Adults

Peer reviewedPreprintPreprintPreprin

‘Stuck in the System’: An Interpretative Phenomenological Analysis of Transmasculine Experiences of Gender Transition in the UK

A gender dysphoria diagnosis is currently required in the UK to access NHS transition-related treatment. However, this approach has been criticised by academics and activists as pathologising, ‘gatekeeping’ transgender identities, and can be viewed by the transgender community as a barrier to necessary medical care. The present research examines transmasculine experiences of gender transition in the UK, focusing on exploring the barriers encountered during identity development and medical transition. Semi-structured interviews were conducted with three individuals, and nine individuals took part in a single focus group. The data were analysed using Interpretative Phenomenological Analysis producing three main themes: ‘Conceptualising Stages of Transition’; ‘NHS Communication and Support’; and ‘Medicalisation, Power and Non-disclosure’. Participants conceptualised access to transition-related treatment as an intrusive and complicated process that negatively impacts identity development. They spoke of barriers such as lack of trans-specific healthcare knowledge, insufficient communication and support from healthcare professionals, and restricted autonomy arising from the pathologisation of trans identities. Results suggest transmasculine individuals may face numerous barriers when trying to access healthcare, and therefore, a move towards the Informed Consent Model could ameliorate many of these barriers and would empower service-users to make informed choices