ESHHEAT-BONA VACANTIA-RIGHT OF STATE TO CLAIM UNCLAIMED ROYALTY PAYMENTS OF A CORPORATION

The State of Arkansas brought suit against defendant to recover various moneys, rents, royalties, credits, and other personal property, which had been unclaimed, forgotten, abandoned, or otherwise lost by-various persons, and which were allegedly in the possession of defendant. The state, not knowing who the previous owners were, submitted interrogatories to defendant which were designed to discover exactly what was in defendant\u27s possession, and who had been the last known owners thereof. The state based its claim on the statutes and on the common law doctrine of bona vacantia. Defendant\u27s demurrer was sustained. On appeal, held, affirmed. The state has no cause of action under the statutes, and there is no common law right of bona vacantia, because there is no allegation that a definitely named article of personal property was held without any known owner nor that a definitely known person had died or disappeared leaving a chose in action and having no known heirs. The interrogatories were not allowed because they were instituted for the purpose of obtaining information on which to base a subsequent proceeding, which subsequent proceeding would be dependent on the information obtained in the first proceeding. State v. Phillips Petroleum Co., (Ark. 1947) 206 S.W. (2d) 771

BILLS AND NOTES-PERSONAL LIABILITY OF AGENT WHO SIGNS NOTE WHICH PRINCIPAL HAS NO LEGAL POWER TO EXECUTE

Defendant gave a note, signed by him in his representative capacity as village president, to plaintiff in payment for services rendered to the village. Defendant signed after he was authorized to do so by a resolution of the village board of trustees. The facts showed that the parties understood the village to be the primary obligor on the note. Actually, the village had no legal power to make such notes and could not have been indebted by them. Plaintiff sued defendant as an individual and won a verdict in the trial court. On appeal, held, reversed. Defendant having signed in a representative capacity was not personally bound, inasmuch as he was given permission by the board of trustees, and because the plaintiff was charged with notice of the village\u27s lack of capacity. Greenlee v. Beaver, (Ill. 1948) 79 N.E. ( 2d) 822

INSURANCE-EFFECT OF INCONTESTABLE CLAUSE IN SUIT FOR REFORMATION OF POLICY

For over twenty years, defendant insurer accepted premiums on a life insurance policy issued to plaintiff. Defendant then discovered that a clerical error had been made in the original policy, as a result of which plaintiff\u27s premium payments were approximately one-half the premiums defendant normally received for the type of policy actually issued. Defendant asked for reformation of the policy on the ground of mistake, and the trial court granted the relief sought. On appeal, held, reversed. The action was barred by the incontestable clause. Richardson v. Travelers Insurance Co., (App. 9th, 1948) 171 F. (2d) 699

QUASI-CONTRACTS -- TAXATION -- RESCISSION OF GIFT FOR FAILURE TO ACHIEVE DONOR\u27S PURPOSE OF MINIMIZING FEDERAL INCOME TAXES

In 1937, plaintiff made a gift of stock in a closed corporation to his wife, the defendant. For two years defendant received cash dividends on the stock transferred to her and paid income taxes thereon. Late in 1938 the corporation was dissolved; the assets were distributed to the shareholders, and a partnership was formed. Defendant continued to report the income received by her from the partnership. In 1946, the Tax Court sustained the contention of the commissioner of internal revenue that the entire income from this partnership was taxable to plaintiff under the doctrine of Commissioner v. Tower. Plaintiff sought rescission of his gift, claiming that the gratuitous transfer had been induced by a. mistaken assumption as to tax consequences. The evidence showed that the prime purpose of the gift was to build up defendant\u27s estate and that the intent to reduce income taxes was only an incidental motive. Relief was denied by the trial court. On appeal, held, affirmed. Since the chief purpose in making the gift was not defeated, plaintiff was not entitled to equitable relief. Lowry v. Kavanagh, 322 Mich. 532, 34 N.W. (2d) 60 (1948)

Determination of hydrogen permeability in commercial and modified superalloys

The results of hydrogen permeability measurements on several iron- and cobalt-base alloys as well as on two long-ranged ordered alloys over the range of 705 to 870 C (1300 to 1600 F) are summarized. The test alloys included wrought alloys N-155, IN 800, A-286, 19-9DL, and 19-9DL modifications with aluminum, niobium, and misch metal. In addition, XF-818, CRM-6D, SA-F11, and HS-31 were evaluated. Two wrought long-range ordered alloys, Ni3Al and (Fe,Ni)3(V,Al) were also evaluated. All tests were conducted at 20.7 MPa pressure in either pure and/or 1% CO2-doped H2 for test periods as long as 133 h. Detailed analyses were conducted to determine the relative permeability rankings of these alloys and the effect of doping, exit surface oxidation, specimen design variations, and test duration on permeability coefficient, and permeation activation energies were determined. The two long-range ordered alloys had the lowest permeability coefficients in pure H2 when compared with the eight commercial alloys and their modifications. With CO2 doping, significant decrease in permeability was observed in commercial alloys--no doped tests were conducted with the long-range ordered alloys

Creep-rupture behavior of candidate Stirling engine iron supperalloys in high-pressure hydrogen. Volume 2: Hydrogen creep-rupture behavior

The creep rupture behavior of nine iron base and one cobalt base candidate Stirling engine alloys is evaluated. Rupture life, minimum creep rate, and time to 1% strain data are analyzed. The 3500 h rupture life stress and stress to obtain 1% strain in 3500 h are also estimated

Cash Transfers, Early Marriage, and Fertility in Malawi and Zambia

There is increasing interest in the ability of cash transfers to facilitate safe transitions to adulthood in low-income settings; however, evidence from scaled-up government programming demonstrating this potential is scarce. Using two experimental evaluations of unconditional cash transfers targeted to ultra-poor and labor-constrained households over approximately three years in Malawi and Zambia, we examine whether cash transfers delayed early marriage and pregnancy among youth aged 14 to 21 years at baseline. Although we find strong impacts on poverty and schooling, two main pathways hypothesized in the literature, we find limited impacts on safe transition outcomes for both males and females. In addition, despite hypotheses that social norms may constrain potential impacts of cash transfer programs, we show suggestive evidence that pre-program variation in social norms across communities does not significantly affect program impact. We conclude with policy implications and suggestions for future research

Rural-urban disparities in the nutritional status of younger adolescents in Tanzania

Research on geographic differences in health focuses largely on children less than five years; little is known about adolescents—and even less regarding younger adolescents—a vulnerable group at a critical stage of the life course. Africa’s rapid population growth and urbanization rates, coupled with stagnant rates of undernutrition, further indicate the need for country-specific data on rural-urban health disparities to inform development policies. This study examined rural-urban disparities in body mass index-for-age-and-sex (BAZ) and height-for-age-and-sex z-scores (HAZ) among younger adolescents in Tanzania. Participants were randomly selected adolescents aged 10–14 years (N = 1,125) residing in Kilosa (rural) and Moshi (urban) districts of Tanzania. Individual and household-level data were collected using surveys and anthropometric data was collected on all adolescents. Age, sex, household living conditions, and assets were self-reported. BAZ and HAZ were calculated using the WHO reference guide. The prevalence of undernutrition was 10.9% among rural and 5.1% among urban adolescents (p\u3c0.001). Similarly, stunting prevalence was greater in rural (64.5%) than urban (3.1%) adolescents (p\u3c0.001). After adjusting for covariates, rural residence was significantly and inversely associated with BAZ (B = -0.29, 95% CI: -0.52, -0.70, p = 0.01), as well as with HAZ (B = -1.79, 95% CI: -2.03, -1.54, p\u3c0.001). Self-identified males had lower BAZ (B = -0.23, 95% CI: -0.34, -0.11, p\u3c0.001) and HAZ (B = -0.22, 95% CI: -0.35, -0.09, p = 0.001) than self-identified female adolescents. Rural-urban disparities in nutritional status were significant and gendered. Findings confirm place of residence as a key determinant of BAZ and HAZ among younger adolescents in Tanzania. Targeted gender-sensitive interventions are needed to limit growth faltering and improve health outcomes in rural settings

A Postmortem Analysis of Embalmed Lungs, a Human Cadaver Study

OBJECTIVE: The human cadaveric study is vital to fully understanding lung pathologies and the prevalence of potentially cancerous neoplasms upon death in the general population. Developing an accurate knowledge of human respiratory neoplastic pathology is vital in furthering the field of respiratory medicine. This study aims to analyze a cohort of lung sets belonging to human cadavers for visible potentially pathogenic neoplasms and contrast this with epidemiological data available for representative populations. METHODS: Cadaveric lungs (n= 20 pairs; 38 individual lungs) were isolated, and gross observations were performed of the parietal surface of both lungs. These samples were part of a collective of over two years worth of cadaveric specimens from the Gross Anatomy laboratory at Philadelphia College of Osteopathic Medicine, South Georgia. Each lung was grossly inspected for suspicious lesions. Lesions were analyzed for prevalence and recorded photographically. The following are the core actions this study performed: Criteria for lesions for the purpose of this study: Visible hyperpigmentation compared to surrounding external surface lung tissue Be at least 2 mm in diameter on at least one axis Flat or raised appearance contrasted with surrounding lung tissue. Photograph a compendium of each donor’s lungs from various approaches. Photos included a clear metric ruler for reference in a standardized approach. Statistical analysis for this cadaveric lung population contrasted with existing epidemiologic data will be performed. Tissue samples from representative lung lesions were sent to the Colquitt Regional Medical Center for processing. Histopathology slides were stained by hematoxylin and eosin stains. Slides were initially viewed by medical students, and a pathologist later confirmed the findings. RESULTS: A total of 20 cadavers were studied with an age range of (58) to (88) years. There were (12) males and (8) females, with a male-to-female ratio of (3:2). Gross observations from 2022 specimens were significantly diverse. Findings include metastatic calcific nodules on superficial surfaces, hemorrhagic pleural cavities, anthracotic streaks, and diffuse tissue texture changes compared to adjacent lobes. The most common histological findings were inflammatory (88.8%), obstructive lung disease, including emphysema (44.4%), pulmonary edema, and congestion (66.6%). Specific findings to certain samples included neoplastic adenocarcinoma, anthracosis, multinucleated giant cells, and potential fungal pathology. Individual lung samples from the 2022 cohort (n=16) were histologically observed and placed in respective categories with prevalence: Edematous and Congestive: 66.66% Inflammatory Processes (Neutrophilic or Lymphocytic): 88.88% Obstructive Lung Disease (COPD/Emphysematous/Chronic Bronchitis): 44.44% Restrictive Lung Disease (Pulmonary Fibrosis): 33.33% Anthracosis: 33.33% Autolyzed samples: 1 Metastatic lung cancer: 2 Primary lung cancer: 1 This is an ongoing study. Lung specimens from 2023 are currently being studied. CONCLUSIONS: Most lung specimens are well preserved in cadavers, providing opportunity for medical students to study lung histology and histopathology. Pathological findings in cadaveric lungs are common findings, either incidental or directly related to the cause of death. Inflammatory conditions in the form of pneumonia are the most frequent cause of death as a terminal complication, and our observations matched expected prevalences