Collapsible Corporations in a Nutshell

Section 331(a) (1) of the Internal Revenue Code provides that acomplete liquidation of a corporation is to be treated by a shareholderas a sale of his stock, and section 334(a) provides that ashareholder\u27s basis for property acquired on a liquidation is itsfair market value at the time of distribution. These long-establishedrules led to the tax avoidance device known as the collapsible corporation with which the Treasury Department has long been concerned.In 1950, Congress enacted a provision designed to dealwith this form of tax avoidance, the predecessor of section 341 ofthe Internal Revenue Code of 1954. This article will examine thedevice known as the collapsible corporation, the manner in whichsection 341 has been used to prevent the conversion of ordinaryincome into capital gain, and the problems flowing from this provision

The Destiny of Net Operating Losses

Professor Eustice opens the discussion with a description of the 1976 amendments to section 382 and the history of other provisions as a backdrop to the proposed changes by the Senate Finance Committee Staff Report. Professor Eustice provides a comprehensive roadmap to the limitations proposed, including how they would operate in practice. Mr. Portney then considers the reform proposals for the net operating loss carryover and the types of considerations that merit discussion in choosing the appropriate restrictions on carryovers. Mr. Portney presents a strong case in favor of simplicity. He argues also that the statute should restrict the use of corporate acquisitions for the purpose of obtaining loss carryovers and suggests methods for accomplishing that sort of restriction. Professor Eustice then discusses alternatives for limiting loss carryovers, one based on the purchase price of the business and the other based on the future income stream from the pool of capital in existence at the time of the acquisition

Identifying the health care-initiated and self-initiated interventions used by women for the management of rectal emptying difficulty secondary to obstructive defecation: a scoping review protocol.

OBJECTIVE: This scoping review aims to identify interventions used by women for the management of rectal emptying difficulty secondary to obstructive defecation. INTRODUCTION: Rectal emptying difficulty is typically a symptom of obstructive defecation syndrome. Even though a range of interventions are already available for this condition, this review is necessary to increase understanding of what interventions women find useful and are acceptable for them. This depth of understanding will facilitate the development of a specific care pathway to support women living with rectal emptying difficulty secondary to obstructive defecation syndrome. INCLUSION CRITERIA: This review will consider studies that include adult women (over 18 years of age) living in the community who have experienced difficulty with rectal emptying secondary to obstructive defecation and who have not had surgical intervention. Exclusion criteria include prolapse surgery and surgical techniques, oral laxatives, vaginal pessaries, cognitive impairment, pregnancy, and those residing in care homes. METHODS: The databases to be searched include MEDLINE, Embase, CINAHL, PsycINFO, Emcare, AMED, Web of Science, Scopus, PROSPERO, Open Grey, ClinicalTrials.gov, International Clinical Trials Registry Platform Search Portal, UK Clinical Trials Gateway, International Standard Randomised Controlled Trial Number Registry, JBI Evidence Synthesis, Epistemonikos, Cochrane Library, and gray literature. Studies conducted in English from any time period will be considered for inclusion. The titles and abstracts will then be screened by two independent reviewers for assessment against the inclusion criteria for the review

Underwater Acoustic Navigation with the WHOI Micro-Modem

The WHOI Micro-Modem is a compact, low-power acoustic transceiver that can provide both acoustic telemetry and navigation. Its size and versatility make it ideal for integration in autonomous underwater vehicles (AUVs). The modem supports the use of both broadband and narrowband transponders for long baseline navigation systems, has a modem-to-modem ranging capability, and can be configured to provide synchronous oneway ranging, when integrated with a precision clock. This paper gives an overview of the different navigation systems supported by the Micromodem and presents the results from field tests conducted on the SeaBED AUV in deployments in Greece, the Bluefin AUV, and whale localizations in the Stellwagen Bank Marine Sanctuary.Peer Reviewedhttp://deepblue.lib.umich.edu/bitstream/2027.42/86053/1/ssingh-27.pd

Towards High-resolution Imaging from Underwater Vehicles

Large area mapping at high resolution underwater continues to be constrained by sensor-level environmental constraints and the mismatch between available navigation and sensor accuracy. In this paper, advances are presented that exploit aspects of the sensing modality, and consistency and redundancy within local sensor measurements to build high-resolution optical and acoustic maps that are a consistent representation of the environment. This work is presented in the context of real-world data acquired using autonomous underwater vehicles (AUVs) and remotely operated vehicles (ROVs) working in diverse applications including shallow water coral reef surveys with the Seabed AUV, a forensic survey of the RMS Titanic in the North Atlantic at a depth of 4100 m using the Hercules ROV, and a survey of the TAG hydrothermal vent area in the mid-Atlantic at a depth of 3600 m using the Jason II ROV. Specifically, the focus is on the related problems of structure from motion from underwater optical imagery assuming pose instrumented calibrated cameras. General wide baseline solutions are presented for these problems based on the extension of techniques from the simultaneous localization and mapping (SLAM), photogrammetric and the computer vision communities. It is also examined how such techniques can be extended for the very different sensing modality and scale associated with multi-beam bathymetric mapping. For both the optical and acoustic mapping cases it is also shown how the consistency in mapping can be used not only for better global mapping, but also to refine navigation estimates.Peer Reviewedhttp://deepblue.lib.umich.edu/bitstream/2027.42/86051/1/hsingh-21.pd

Optical Telecommunications-Band Clock based on Neutral Titanium Atoms

We propose an optical clock based on narrow, spin-forbidden M1 and E2 transitions in laser-cooled neutral titanium. These transitions exhibit much smaller black body radiation shifts than those in alkaline earth atoms, small quadratic Zeeman shifts, and have wavelengths in the S, C, and L-bands of fiber-optic telecommunication standards, allowing for integration with robust laser technology. We calculate lifetimes; transition matrix elements; dynamic scalar, vector, and tensor polarizabilities; and black body radiation shifts of the clock transitions using a high-precision relativistic hybrid method that combines a configuration interaction and coupled cluster approaches. We also calculate the line strengths and branching ratios of the transitions used for laser cooling. To identify magic trapping wavelengths, we have completed the largest-to-date direct dynamical polarizability calculations. Finally, we identify new challenges that arise in precision measurements due to magnetic dipole-dipole interactions and describe an approach to overcome them. Direct access to a telecommunications-band atomic frequency standard will aid the deployment of optical clock networks and clock comparisons over long distances.Comment: 5 pages, 2 figures main text; 8 pages, 3 figures supplementary tex

Women's experiences of managing digitation: do we ask enough in primary care?

The aim of this paper was to consider the available evidence for the current management of pelvic organ prolapse, which is a common presentation in primary care. However, not all women will present, only presenting when symptoms become bothersome. Particular attention was paid to understanding the problem of rectocele and its influence on obstructive defaecation symptoms. The burden of rectocele and its consequences are not truly known. Furthermore, healthcare professionals may not always enquire about bowel symptoms and patients may not disclose them. Complex emotions around coping and managing stress add to the challenges with seeking healthcare. Therefore, the impact on the lived experience of women who have difficulty with rectal emptying can be significant. The review identified a dearth of knowledge about women living with the problem of obstructive defaecation resulting in the use of digitation. Improving the management of digitation, an under-reported problem, is necessary to improve the quality of life for women. Primary care needs to increase access to conservative measures for women struggling with bothersome symptoms, such as constipation, the need to digitate or anxiety

A perspective on emerging automotive safety applications, derived from lessons learned through participation in the DARPA Grand Challenges

This paper reports on various aspects of the Intelligent Vehicle Systems (IVS) team's involvement in the recent 2007 DARPA Urban Challenge, wherein our platform, the autonomous “XAV-250,'' competed as one of the 11 finalists qualifying for the event. We provide a candid discussion of the hardware and software design process that led to our team's entry, along with lessons learned at this event and derived from participation in the two previous Grand Challenges. In addition, we give an overview of our vision-, radar-, and LIDAR-based perceptual sensing suite, its fusion with a military-grade inertial navigation package, and the map-based control and planning architectures used leading up to and during the event. The underlying theme of this article is to elucidate how the development of future automotive safety systems can potentially be accelerated by tackling the technological challenges of autonomous ground vehicle robotics. Of interest, we will discuss how a production manufacturing mindset imposes a unique set of constraints upon approaching the problem and how this worked for and against us, given the very compressed timeline of the contests. © 2008 Wiley Periodicals, Inc.Peer Reviewedhttp://deepblue.lib.umich.edu/bitstream/2027.42/61244/1/20264_ftp.pd

Color-accurate underwater imaging using perceptual adaptive illumination

Capturing color in water is challenging due to the heavy non-uniform attenuation of light in water across the visible spectrum, which results in dramatic hue shifts toward blue. Yet observing color in water is important for monitoring and surveillance as well as marine biology studies related to species identification, individual and group behavior, and ecosystem health and activity monitoring. Underwater robots are equipped with motor control for large scale transects but they lack sensors that enable capturing color-accurate underwater images. We present a method for color-accurate imaging in water called perceptual adaptive illumination. This method dynamically mixes the illumination of an object in a distance-dependent way using a controllable multi-color light source. The color mix compensates correctly for color loss and results in an image whose color composition is equivalent to rendering the object in air. Experiments were conducted with a color palette in the pool and at three different coral reefs sites, and with an underwater robot collecting image data with the new sensor.United States. Office of Naval Research (Project N000140911051