Gifts Effected by Written Instrument: Faith Lutheran Home v. Veis

Gifts Effected By Written Instrument: Faith Lutheran Home v. Vei

Securities: The Private Offering Exemption and Rule 146

Securities: The Private Offering Exemption And Rule 14

Rethinking Imposition of a Legal Duty to Correct Material Tax Return Errors

I. Introduction ... A. Propriety of a Duty to Correct Material Tax Return Errors ... B. Penalty Structure and Statutes of Limitations ... C. Article Organization II. Merits of an Amended Return Obligation ... A. Current Lack of a Duty to Correct Tax Return Errors ... B. Justifications for Requiring Taxpayer Correction of Material Errors ... C. Constitutional Barriers to an Amended Return Obligation III. Definition of a Proposed Amended Return Obligation … A. Definition of “Error” ... 1. Return Positions Less Likely than Not to Prevail ... 2. Retroactive Changes in the Law ... B. “Materiality” Defined ... 1. Basic Definition ... 2. “Materiality” of Multiple Errors ... 3. “Materiality” of Errors with No Impact on Tax Liability ... C. Taxpayer’s “Knowledge” of an Error and a Duty to Investigate IV. Amended Return Obligation and the Penalty Structure ... A. Current Penalty Structure ... B. Penalties: A Normative Approach ... 1. Parity Structure Defined ... 2. Existing Penalties Contrasted with a Parity Structure ... C. Penalty Recommendations: Obligatory Amended Returns Filed ... 1. Abrogation of Penalty Exposure for Nonfraudulent Errors Voluntarily Corrected ... 2. Nonabrogation of Penalty Exposure for Fraudulent Errors ... a. Immunization from Fraud Penalties Undermining the Duty to File a Correct Return ... b. Lesser Appeal of Relief for Taxpayers Committing Fraud ... c. Fraud Penalty Relief Unlikely to Enhance Tax Compliance ... d. Difficulty of Formulating a Workable Rule That Waives Criminal Fraud Penalties ... 3. Countervailing Considerations ... a. Fairness of Compelling Taxpayers to Provide Evidence of Fraudulent Conduct ... b. Inhibiting Effect on Taxpayers Who Fear Innocent Errors Will Be Treated as Fraudulent ... D. Penalty Recommendations: Breaches of a Duty to Amend ... 1. A Parity Structure Favored ... 2. No Double Penalty ... 3. Reasonable Opportunity to Comply with a Duty to Amend V. Amended Return Obligation and Statutes of Limitations ... A. Current Statutes of Limitations ... B. Limitations Periods: A Normative Approach ... C. Limitations Period Recommendations ... 1. Nonfraudulent Original Returns ... 2. Fraudulent Original Returns VI. Conclusion

Agglomeration and labour markets: the impact of transport investments on labour market outcomes

The book brings together contributions by scholars from several countries and different “sister” disciplines (Economic Geography, Urban and Regional Economics, Innovation Studies) with different approaches to the same crucial issue: how geography, culture and institutions influence regional economic performance. It includes a number of relevant insights into these complex relations covering different-though complementary-streams of literature in order to emphasize their points of contact and areas of consensus (or disagreement). The role of institutional and cultural factors in shaping regional economic dynamics is analysed together with the impact of clusters, accessibility, urbanization processes and localised inter-firm linkages. The dynamic interactions of economic agents across space are also explored in depth by analysing the geography of trade flows, labour and capital mobility. Empirical analyses cover the whole European Union with some chapters focused on specific European countries but also on non-European and emerging economies. The book effectively demonstrates that regional development is a complex and multifaceted phenomenon, the in-depth understanding of which calls for the simultaneous consideration of a variety of phenomena and the structural characteristics of places and agents. The understanding of regional economic performance hence calls for an explicit consideration of both “hard” and “soft ” factors of development, especially in terms of geography, culture and institutions

Genome-wide DNA methylation analysis of patients with imprinting disorders identifies differentially methylated regions associated with novel candidate imprinted genes

BACKGROUND: Genomic imprinting is allelic restriction of gene expression potential depending on parent of origin, maintained by epigenetic mechanisms including parent of origin-specific DNA methylation. Among approximately 70 known imprinted genes are some causing disorders affecting growth, metabolism and cancer predisposition. Some imprinting disorder patients have hypomethylation of several imprinted loci (HIL) throughout the genome and may have atypically severe clinical features. Here we used array analysis in HIL patients to define patterns of aberrant methylation throughout the genome. DESIGN: We developed a novel informatic pipeline capable of small sample number analysis, and profiled 10 HIL patients with two clinical presentations (Beckwith–Wiedemann syndrome and neonatal diabetes) using the Illumina Infinium Human Methylation450 BeadChip array to identify candidate imprinted regions. We used robust statistical criteria to quantify DNA methylation. RESULTS: We detected hypomethylation at known imprinted loci, and 25 further candidate imprinted regions (nine shared between patient groups) including one in the Down syndrome critical region (WRB) and another previously associated with bipolar disorder (PPIEL). Targeted analysis of three candidate regions (NHP2L1, WRB and PPIEL) showed allelic expression, methylation patterns consistent with allelic maternal methylation and frequent hypomethylation among an additional cohort of HIL patients, including six with Silver–Russell syndrome presentations and one with pseudohypoparathyroidism 1B. CONCLUSIONS: This study identified novel candidate imprinted genes, revealed remarkable epigenetic convergence among clinically divergent patients, and highlights the potential of epigenomic profiling to expand our understanding of the normal methylome and its disruption in human disease