Taxation- Federal Income Tax - Deductible Contributions to Nonqualified Profit-Sharing Plans

In 1942 plaintiff employer adopted a profit-sharing plan under which a percentage of each year\u27s profits was to be deposited in irrevocable trusts for distribution to its employees in succeeding years. The plan was not qualified under the Internal Revenue Code. Although under the terms of the trusts each employee\u27s rights in the fund vested at the time the contribution was made by the employer, these rights would be forfeited by voluntary resignation prior to a fixed date. In 1945 plaintiff deducted the amount contributed to the trust in that year as a contribution to a non-qualified profit-sharing plan under subsection (D) of section 23 (p) (1), but the Commissioner of Internal Revenue disallowed any deduction in that or any other year for amounts contributed to or paid from any of the funds, alleging that at the time the contribution was made to the trust the rights of the employees were forfeitable. In an action to recover overpayment of income and excess profits taxes, held, Commissioner\u27s determination overruled, and recovery allowed, one judge dissenting. Under subsection (D) of section 23 (p) (1), plaintiff is allowed to deduct in 1945 not the amount contributed to the trust in that year, but rather the amount actually paid from the trust to the employee-beneficiaries in that year, because nonforfeitability in that subsection refers to the time of payment from the trust, and not to the time of payment to the trust. Russell Manufacturing Co. v. United States, (Ct. Cl. 1959) 175 F. Supp. 159

Master of Science

thesisThis study explored the combined impact of family and classroom contexts on middle school students' experience of flow and undivided interest while doing schoolwork. Flow is an intrinsically motivating experience triggered by high challenges and skills; undivided interest is an experience characterized by high interest and high goal importance. Approximately 312 middle school students at 10 schools filled out questionnaires and responded to the Experience Sampling Method (ESM), a method that uses programmable watches to signal students multiple times a day in their everyday contexts. Students' questionnaire responses on support and challenge at home were used to classify family contexts as either authoritative or nonauthoritative (i.e., authoritarian, permissive, or uninvolved); students' ESM responses on support and challenge at school were used to classify classroom contexts as authoritative or nonauthoritative. Two different ESM measures (N = approx. 4000) were also used to assess students' flow and undivided interest while doing schoolwork. The present study examined four distinct contextual combinations (authoritative family + authoritative classroom; authoritative family + nonauthoritative classroom; nonauthoritative family + authoritative classroom; and nonauthoritative family + nonauthoritative classroom) and proposed two main hypotheses: 1) that students who perceived their family as authoritative would more often perceive their classrooms as authoritative; and 2) students in the authoritative family/authoritative classroom group would report more flow and undivided interest than students in the other three family-classroom combinations. Results of chi-square analyses and follow-up contrasts revealed support for the first hypothesis: Students who perceived their home environment as authoritative more often reported feeling supported and challenged in their classrooms at school. Partial support was found for the second hypothesis: Male students in the authoritative family/authoritative classroom group reported the most flow and undivided interest. For the sample as a whole, however, immediate conditions in the classroom were the most predictive of students' flow and undivided interest at school. The implications of these findings and plans for further research are discussed

A Phenomenological Study of Graduated Nursing Student Athletes\u27 Experiences Balancing Academics and Athletics

The purpose of this transcendental phenomenological study is to describe the lived experiences of eleven graduated nursing student athletes who completed traditional, four-year nursing programs while concurrently finishing four years of athletic eligibility in their respective sport at three private, Christian, Midwest universities and across three different competitive collegiate athletic divisions. The theories guiding this study are Tinto’s Theory of Individual Departure from Institutions of Higher Learning, Astin’s Theory of Student Involvement, and Lazarus and Folkman’s Transactional Model of Stress Response, as they relate to student athletes’ persistence to graduation and to nursing students who reportedly experience higher levels of stress than other college students. Participants were purposefully selected to answer the following: How do graduated nursing student athletes describe their experiences in balancing sports and academics while completing a traditional, four-year nursing program and participating in intercollegiate sports? Data collection was conducted using journaling, semi-structured individual interviews, and focus groups. Confidentiality was maintained by using pseudonyms for all colleges and participants. Data analysis was conducted via pattern, theme, and content analysis. Validity and trustworthiness were established via expert and member reviews, as well as triangulation of participant groups, data sources, audit trails, enumeration tables, and inclusion of participant quotes

Constitutional Law - Governmental Immunity - Immunity of Agent of Federal Government to State Taxation

E. I. du Pont de Nemours and Company contracted with the Atomic Energy Commission to construct and operate the Savannah River Project for development of the hydrogen bomb for a fee of one dollar. Under the contract du Pont was to purchase all materials and supplies with funds furnished by the United States, title to vest in the government immediately when it passed from the vendor. South Carolina attempted to apply its sales and use taxes to these purchases. In an action by the United States and du Pont before a statutory three-judge district court to enjoin collection of these taxes, held, injunction granted, one judge dissenting. The purchases by du Pont are exempt from state taxation because du Pont was acting as an agent of the federal government. United States v. Livingston, 179 F. Supp. 9 (E.D. S.C. 1959)

Trust in Private and Common Property Experiments

We report the results from a series of experiments designed to investigate behavior in two settings that are frequently posited in the policy literature as generating different outcomes: private property and common property. The experimental settings closely parallel earlier experimental studies of the investment or trust game. The primary research question relates to the effect of the initial allocation of property rights on the level of trust that subjects will extend to others with whom they are linked. We find that assigning the initial endowments as common property of each of N pairs of a first mover and second mover leads to marginally greater cooperation or trust than when the initial endowments are fully owned by the two individual movers as their, respective, private property. Subjectsâ?? decisions are also shown to be correlated with attitudes toward trust and fairness that are measured in post-experiment questionnaires.

Conserved hydrogen bonding in tetrahydrocarbazolone derivatives: influence of solution-state assembly on crystal form nucleation

Two tetrahydocarbazolone derivatives were found to show multiple unsolvated crystal forms. A persistent dimer motif was detected in solution by FTIR spectroscopy that is maintained in the kinetic crystal forms. Rationally introduced steric bulk induces the formation of a more stable catemeric form

Saturation of intersubband transitions in p-doped GaAs/AlGaAs quantum wells

Optical saturation experiments have been performed on hh1-hh2 intersubband transitions in two samples of p-doped GaAs/AlGaAs quantum wells. The transitions had energies of 183 and 160 meV and the measured population relaxation times were 2±1.5 and 0.3±0.1 ps, respectively. Modeling of the quantum wells with a 6×6 k·p method shows that intersubband scattering by LO phonons can account for these relaxation times. The valence bandstructure is typically more complicated than the conduction bandstructure in a quantum well but these measurements show that LO phonons are the dominant intersubband scattering mechanism in both cases