COURTS-JURISDICTION-CONSTITUTIONALITY OF STATUTE ESTABLISHING JURISDICTION OVER NONRESIDENT CONDUCTING BUSINESS IN STATE THROUGH RESIDENT AGENT

Defendant, a resident of Utah, sued petitioner, a resident of California, to recover construction costs and contractor\u27s fee for the erection of a building at petitioner\u27s Utah place of business. In accordance with a statute of Utah providing that jurisdiction over a nonresident individual doing business in the state could be obtained in all actions arising out of the conduct of the business by serving process on the resident agent managing the business, summons was served on the petitioner\u27s Utah manager. Petitioner appeared specially and moved to quash the summons for lack of jurisdiction, which motion was denied. He then obtained an alternative writ of prohibition from the Supreme Court of Utah to stop proceedings in the district court. On an order to show cause why the alternative writ should not be made permanent, held, the writ should be recalled. The statute did not deny due process; the question of retroactive application was not raised because there was sufficient business activity subsequent to its effective date. Wein v. Crockett, (Utah I948) I95 P. (2d) 222

TAXATION-LIENS-NATURE OF FEDERAL ESTATE TAX LIEN

At the time of his death, decedent owned certain land in fee simple. His executrix, authorized by an order of the probate court, sold the land to herself as an individual. Subsequently, the United States began condemnation proceedings against the land, paying an award into court. Before distribution of this award was ordered, the executrix in her individual capacity and as ostensible owner was permitted in accordance with statute to withdraw a part of this award. The withdrawal was made without prejudice to her right to the remainder if it proved more than sufficient to satisfy the claims of other parties in interest, and without effect on her duty to refund if it proved inadequate. The United States then filed a petition for distribution of the award, naming with the executrix, as possible parties in interest, the Commissioner and Collector of Internal Revenue, on the ground that a lien for unpaid federal estate taxes might have attached. In answering, the commissioner asserted such a lien on an amount in excess of that part of the award remaining in court. The district court concluded that the sale of the land to the executrix had not divested the lien and that she was therefore liable to refund an amount sufficient to satisfy the claim of the United States. On appeal by the executrix, held, affirmed. Smythe v. United States, (C.C.A. 1st, 1948) 169 F. (2d) 49

INTERNATIONAL LAW-SEIZURE OF FOREIGN VESSELS ON THE HIGH SEAS

After World War I, the Allied Powers under Article XXII of the Covenant of the League of Nations designated Great Britain mandatary of Palestine, providing inter alia that, as far as possible without prejudice to the rights of the then residents of Palestine, steps were to be taken to facilitate Jewish immigration. A High Commissioner for Palestine was appointed, who, by the authority vested in him under the mandate, promulgated a general ordinance regulating immigration. It was provided therein that any British government ship might board any vessel to detain and examine persons reasonably believed to be seeking to enter the country in violation of this regulation. It was further provided that the master of a vessel attempting to bring such persons into the country would be guilty of the criminal offense of abetting illegal immigration and that the ship used for such purpose would be forfeited. If no criminal proceedings were instituted against the master, forfeiture might be confirmed by petition of the Attorney General to a district court of Palestine

INTERNATIONAL LAW-PRIZE LAW-SEIZURE OF PORT AS EFFECTING CAPTURE OF SHIPS IN PORT

When the Italian port of Tripoli was captured by the British in January, 1943, two privately owned Italian vessels were lying aground in the harbor. Though the Italian armistice was signed in September, 1943, and British naval authorities early in 1944 ordered the seizure in prize of all salvable vessels, nothing was done with respect to these vessels until February 3, 1947. At that time they were placed under the jurisdiction of the Prize Court of England. On February 10, 1947, the Treaty of Peace with Italy was signed and became effective on September 15, 1947. By act of Parliament, implemented by Treaty of Peace (Italy) Order, 1948, it became the law of Great Britain. Meanwhile, in May, writs in prize had been issued for the condemnation of the two vessels. In 1948, the Italian owners appeared as claimants and sought their release. Article 76 of the treaty provides that Italy waives all claims of any description against the Allied and Associated Powers on behalf of the Italian government or Italian nationals arising directly out of the war or out of actions taken because of the existence of a state of war in Europe after September 1, 1939 . . . including . . . (d) claims arising out of the exercise or purported exercise of belligerent rights. 2. The provisions of this article shall bar, completely and finally, all claims of the nature referred to herein, which will be henceforward extinguished, whoever may be the parties in interest . . . . It was the owners\u27 contention that capture was not effected until after the armistice, and was therefore neither an actual nor purported exercise of belligerent rights within the meaning of the treaty. Held, condemnation ordered. Assuming that the armistice terminated the right to make captures, capture was purportedly and actually accomplished by the seizure of the port, so the treaty operates to bar the owners\u27 claims. The Bellaman, [1948] 2 All Eng. L. Rep. 679

Time-dependent quantum many-body theory of identical bosons in a double well: Early time ballistic interferences of fragmented and number entangled states

A time-dependent multiconfigurational self-consistent field theory is presented to describe the many-body dynamics of a gas of identical bosonic atoms confined to an external trapping potential at zero temperature from first principles. A set of generalized evolution equations are developed, through the time-dependent variational principle, which account for the complete and self-consistent coupling between the expansion coefficients of each configuration and the underlying one-body wave functions within a restricted two state Fock space basis that includes the full effects of the condensate's mean field as well as atomic correlation. The resulting dynamical equations are a classical Hamiltonian system and, by construction, form a well-defined initial value problem. They are implemented in an efficient numerical algorithm. An example is presented, highlighting the generality of the theory, in which the ballistic expansion of a fragmented condensate ground state is compared to that of a macroscopic quantum superposition state, taken here to be a highly entangled number state, upon releasing the external trapping potential. Strikingly different many-body matter-wave dynamics emerge in each case, accentuating the role of both atomic correlation and mean-field effects in the two condensate states.Comment: 16 pages, 5 figure

Variation in Treatment for Trapeziometacarpal Arthrosis

Background: Treatment recommendations for trapeziometacarpal (TMC) arthrosis are highly variable from surgeon to surgeon. This study addressed the influence of viewing radiographs on a decision to offer surgery for TMC arthrosis. Methods: In an online survey, 92 hand surgeons viewed clinical scenarios and were asked if they would offer surgery to 30 patients with TMC arthrosis. Forty-two observers were randomly assigned to review clinical information alone and 50 to review clinical information as well as radiographs. The degree of limitation of daily activities, time since diagnosis, prior treatment, pain with grind, crepitation with grind, and metacarpal adduction with metacarpophalangeal hyperextension were randomized for each patient scenario to determine the influence of these factors on offers of surgery. A cross-classified binary logistic multilevel regression analysis identified factors associated with surgeon offer of surgery. Results: Surgeons were more likely to offer surgery when they viewed radiographs (42% vs. 32%, P = 0.01). Other factors associated variation in offer of surgery included greater limitation of daily activities, symptoms for a year, prior splint or injection, deformity of the metacarpophalangeal joint. Factors not associated included limb dominance, prominence of the TMC joint, crepitation with the grind test, and pinch and grip strength. Conclusion: Surgeons that view radiographs are more likely to offer surgery to people with TMC arthrosis. Surgeons are also more likely to offer surgery when people do not adapt with time and nonoperative treatment. Given the notable influence of surgeon bias, and the potential for surgeon and patient impatience with the adaptation process, methods for increasing patient participation in the decision-making process merit additional attention and study

Irreversible Field Induced Magnetostriction at Temperatures Above and Below the Order-Disorder Transition in Single Crystal Tb5Si2.2Ge1.8

This paper reports on the behavior of single crystal Tb5Si2.2Ge1.8 in the vicinity of its order-disorder and order-order phase transition from a higher temperature paramagnetic∕monoclinic state to a lower temperature ferromagnetic∕orthorhombic state. Measurements have been made of thermal and field induced changes in strain along the crystallographic a axis. The material exhibits large strains of up to 1500 ppm when a magnetic field is applied to it in its paramagnetic state but much smaller strains when a field is applied to it in its ferromagnetic state. These field induced strains are different from conventional magnetostriction because they result mostly from the change in crystal structure. As a result of this the field induced strain changes that accompany the phase transitions of this material are not fully reversible. The shape and slope of the strain versus magnetic field curves were distinctly different depending on whether the material started from above the Curie temperature (where the application of a magnetic field of sufficient strength induced a structural phase transformation) or started from below the Curie temperature (where the application of a field merely stabilized the existing magnetic order)

Techno-economic analysis of biogas upgrading via amine scrubber, carbon capture and ex-situ methanation

Biogas upgraded to biomethane can provide a renewable gaseous transport fuel and is one of the proposed solutions in meeting the renewable energy supply in transport targets set under the EU Renewable Energy Directive. The upgrading process for biogas involves the removal of CO2. Amine scrubbing is one traditional method of upgrading that is applied due to its low methane slippage and its capability to provide a high purity renewable methane product. However, new technologies such as power to gas (P2G) can also upgrade biogas through biological methanation by combining the CO2 in biogas with H2 to produce renewable methane. The H2 for P2G can be produced through electrolysis of renewable electricity. Through simulation software – SuperPro Designer, the economics of different pathways for upgrading biogas from a grass silage and slurry fed digester are analysed and compared in this paper. Three scenarios were investigated: biogas upgrading through amine scrubbing (scenario 1); biogas upgrading through amine scrubbing with CO2 directed to ex-situ biological methanation (scenario 2) and biogas upgrading through ex-situ biological methanation only (scenario 3). The results show that at a net present value of zero, the minimum selling price (MSP) per m3 of renewable methane for scenario 1, 2 and 3 is €0.76; €1.50 and €1.43, respectively (with an electricity price to produce H2 of €0.10/kWh and a grass silage production cost of €27/t). The electricity price has a significant effect on the cost of renewable methane in both scenarios 2 and 3. The MSP reduces to €1.09 and €1.00 per m3 of renewable methane, respectively for scenarios 2 and 3, if the electricity price is reduced to €0.05/kWh. Since the renewable methane MSP from scenario 2 is higher than scenario 3, it is suggested that direct biogas injection to the methanation reactor is financially more attractive than capturing CO2 from biogas and feeding it to the methanation step. The MSP of renewable methane from both scenarios 2 and 3 are significantly higher than that of scenario 1. However, when considering climate change mitigation, balancing of the electricity network and storage of surplus electricity, utilising P2G can offset some of these costs. The cost of H2 is a significant factor in determining the cost of renewable methane

A variant in LIN28B is associated with 2D:4D finger-length ratio, a putative retrospective biomarker of prenatal testosterone exposure

The ratio of the lengths of an individual's second to fourth digit (2D:4D) is commonly used as a noninvasive retrospective biomarker for prenatal androgen exposure. In order to identify the genetic determinants of 2D:4D, we applied a genome-wide association approach to 1507 11-year-old children from the Avon Longitudinal Study of Parents and Children (ALSPAC) in whom 2D:4D ratio had been measured, as well as a sample of 1382 12- to 16-year-olds from the Brisbane Adolescent Twin Study. A meta-analysis of the two scans identified a single variant in the LIN28B gene that was strongly associated with 2D:4D (rs314277: p = 4.1 108) and was subsequently independently replicated in an additional 3659 children from the ALSPAC cohort (p = 1.53 106). The minor allele of the rs314277 variant has previously been linked to increased height and delayed age at menarche, but in our study it was associated with increased 2D:4D in the direction opposite to that of previous reports on the correlation between 2D:4D and age at menarche. Our findings call into question the validity of 2D:4D as a simplistic retrospective biomarker for prenatal testosterone exposure