A History of Tax Regulation Prior to the Administrative Procedure Act

The relationship of the Administrative Procedure Act (APA) to tax administration has been the subject of increasing scrutiny from scholars and courts. Some of this scrutiny has critiqued the long-held view of the Department of Treasury that tax regulations issued under the general grant of authority in I.R.C. § 7805(a) are interpretative regulations within the meaning of the APA. This Article reviews the almost 150–year history of tax administration before the enactment of the APA to show the origins and basis for this long-held view. The Article also argues that the application of the general terms of the APA to tax administration must be informed by this pre–APA history of tax regulation

Measuring customer satisfaction and understanding customer effort in a B2B context

Our members asked us to investigate a number of aspects of Customer Satisfaction measurement in a Business-to-Business (B2B) context. Specific questions were:- What are the different metrics of customer satisfaction that are measured in a BTB relationship? Which are used the most? Which are the most effective? Do they vary by type of company? Are there new ways to measure customer satisfaction that more closely reflects their customer experience? What does customer effort mean in a B2B relationship? How do we identify where we are not easy to do business with? What do we have to do differently? Our approach to the subject was to review existing literature and previous research and then to conduct an exploratory qualitative review into the subject by conducting interviews with a range of B2B companies and a sample of their customers. The purpose behind the interviews was to try to answer the above questions and to identify if there were opportunities for more in-depth research in the future. The project demonstrates that the B2B companies compile and use a customer satisfaction rating for their business-to-business relationships but that there is little commonality between companies in both the full range of questions asked and the scales used for the individual questions. All of the companies use a mixture of global and dimensional measures (see literature review in section 2). There is some scope for manipulation of the customer satisfaction process in most companies so the results have to be treated with a degree of caution. However, the companies believe that they are getting good positive and negative feedback from the process so they see significant value from it. Where the customer satisfaction rating falls below an acceptable level, which differs by company, responses are shared with the customer as part of the regular relationship meeting and a monitored action plan is the normal result. In addition, in most cases, common issues are identified at company level and considered for improvement programs. The questions about customer effort showed that companies in general consider themselves more difficult to do business with than their customers do. Analysis of both company and customer views of what was ‘easy’ and what was ‘difficult’ about the relationship identified a number of interactions that could potentially be the subject of process improvement initiatives. It appears from this research that the inclusion of customer effort questions would benefit the customer satisfaction process for B2B companies and a number of best practise approaches were identified from this and previous research

Arthroscopic management of an intraarticular osteochondroma of the hip.

The role of hip arthroscopy in the management of femoroacetabular impingement (FAI) has been advancing rapidly. In this case report, we describe the use of hip arthroscopy to successfully treat a femoral neck osteochondroma that caused a symptomatic labral tear in a 37 year old woman. Hip arthroscopy offers several advantages to surgical dislocation of the hip in the management of intraarticular pathology and FAI. Hip arthroscopy is minimally invasive without the significant trauma to hip musculature, is useful in treatment of labral tears generated by FAI, and can be used to resect small lesions on the femoral head

Discovering SUSY with m02<0m_0^2 < 0 in the First LHC Physics Run

In minimal supergravity, the parameter space where the slepton is the LSP is usually neglected, because of strong constraints on charged dark matter. When the gravitino is the true LSP, this region avoids these constraints and offers spectacular collider signals. We investigate this scenario for the LHC and find that a large portion of the ignored mSugra parameter space can lead to discovery within the first physics run, with 1-4 $\text{fb}^{-1}$ of data. We find that there are regions where discovery is feasible with only 1 day of running

Power laws, memory capacity, and self-tuned critical branching in an LIF model with binary synapses

Both fluctuations and distributions of spontaneous neural spiking activity have been observed to closely follow a variety of power laws. Multiple explanations have been offered for each observation, but few lead to mechanisms that encompass their widespread occurrence. A canonical, leaky integrate-and-fire model is presented in which synapses are updated based on the timing of pre- and post-synaptic spikes in order to maintain a state of critical branching. Results showed that 1) the self-tuning algorithm maintained critical branching under a range of parameters; 2) power laws were obtained in spiking activity fluctuations (1/f scaling), size distributions of network bursts (neural avalanches), and temporal correlations in interspike intervals (Allan factor); 3) power laws disappeared once the self-tuning algorithm was disabled; and 4) critical branching was adaptive in that it maximized the network&#x2019;s memory capacity when assessed as a liquid state machine

Hepatitis C Diagnoses in an American Indian Primary Care Population

BACKGROUND: Despite large disparities in the burden of chronic liver disease, data on hepatitis C virus (HCV) infection among American Indians (AIs) are lacking. We reviewed hepatitis C diagnoses in 35,712 AI/AN primary care patients. MAIN FINDINGS: At least one HCV-associated ICD-9 code was recorded in 251 (1%) patients between October 1, 2001 and September 30, 2003. An HCV enzyme-linked immunoassay (HCVEIA) was sent in 209 (83.0%); 206/209 (99%) were positive. Confirmatory testing was performed in 144/206 (70%) HCV-EIA positive patients; HCV infection was confirmed in 144 (100%). In the 90/144 (63%) charts with risk factor documentation, injection drug use was the most common risk factor (61/90, 68%). Deficiencies were present in hepatitis B and HIV testing, and hepatitis A and B vaccination. PRINCIPAL CONCLUSIONS: Improvements in laboratory workup of HCV and co-infections, risk factor ascertainment and documentation, and adult vaccination are needed to address HCV effectively in this population

Goldilocks Supersymmetry: Simultaneous Solution to the Dark Matter and Flavor Problems of Supersymmetry

Neutralino dark matter is well motivated, but also suffers from two shortcomings: it requires gravity-mediated supersymmetry breaking, which generically violates flavor constraints, and its thermal relic density \Omega is typically too large. We propose a simple solution to both problems: neutralinos freezeout with \Omega ~10-100, but then decay to ~1 GeV gravitinos, which are simultaneously light enough to satisfy flavor constraints and heavy enough to be all of dark matter. This scenario is naturally realized in high-scale gauge-mediation models, ameliorates small scale structure problems, and implies that ``cosmologically excluded'' models may, in fact, be cosmologically preferred.Comment: 4 pages; v2: references added; v3: published versio