Проблемні питання захисту прав платників податків

Досліджено правові та організаційні проблеми забезпечення прав платників податків в Україні, проаналізовано права платників щодо адміністративного та судового оскарження рішень податкових органів. Наведено світовий досвід і пропозиції щодо посилення захисту прав платників податків.Исследованы правовые и организационные проблемы обеспечения прав плательщиков налогов в Украине, проанализированы права налогоплательщиков при административном и судебном обжаловании решений налоговых органов. Приведены мировой опыт и предложения по усилению защиты прав налогоплательщиков.The paper studies the legal and organizational problems concerning ensuring the taxpayers rights in Ukraine, analyses the rights of taxpayers in the administrative and judicial tax appeals. The world experience is described, and proposals to strengthen the protection of taxpayers rights are offered

A Model for Particle Microphysics, Turbulent Mixing, and Radiative Transfer in the Stratocumulus-Topped Marine Boundary Layer and Comparisons with Measurements

A detailed 1D model of the stratocumulus-topped marine boundary layer is described. The model has three coupled components: a microphysics module that resolves the size distributions of aerosols and cloud droplets, a turbulence module that treats vertical mixing between layers, and a multiple wavelength radiative transfer module that calculates radiative heating rates and cloud optical properties. The results of a 12-h model simulation reproduce reasonably well the bulk thermodynamics, microphysical properties, and radiative fluxes measured in an approx. 500-m thick, summertime marine stratocumulus cloud layer by Nicholls. However, in this case, the model predictions of turbulent fluxes between the cloud and subcloud layers exceed the measurements. Results of model simulations are also compared to measurements of a marine stratus layer made under gale conditions and with measurements of a high, thin marine stratocumulus layer. The variations in cloud properties are generally reproduced by the model, although it underpredicts the entrainment of overlying air at cloud top under gale conditions. Sensitivities of the model results are explored. The vertical profile of cloud droplet concentration is sensitive to the lower size cutoff of the droplet size distribution due to the presence of unactivated haze particles in the lower region of the modeled cloud. Increases in total droplet concentrations do not always produce less drizzle and more cloud water in the model. The radius of the mean droplet volume does not correlate consistently with drizzle, but the effective droplet radius does. The greatest impacts on cloud properties predicted by the model are produced by halving the width of the size distribution of input condensation nuclei and by omitting the effect of cloud-top radiative cooling on the condensational growth of cloud droplets. The omission of infrared scattering produces noticeable changes in cloud properties. The collection efficiencies for droplets less than 30-micrometers radius, and the value of the accommodation coefficient for condensational droplet growth, have noticeable effects on cloud properties. The divergence of the horizontal wind also has a significant effect on a 12-h model simulation of cloud structure. Conclusions drawn from the model are tentative because of the limitations of the 1D model framework. A principal simplification is that the model assumes horizontal homogeneity, and, therefore, does not resolve updrafts and downdrafts. Likely consequences of this simplification include overprediction of the growth of droplets by condensation in the upper region of the cloud, underprediction of droplet condensational growth in the lower region of the cloud, and underprediction of peak supersaturations

Light emission intensities of luminescent Y2O3:Eu and Gd2O3:Eu particles of various sizes

There is great technological interest in elucidating the effect of particle size on the luminescence efficiency of doped rare earth oxides. This study demonstrates unambiguously that there is a size effect and that it is not dependent on the calcination temperature. The Y2O3:Eu and Gd2O3:Eu particles used in this study were synthesized using wet chemistry to produce particles ranging in size between 7 nm and 326 nm and a commercially available phosphor. These particles were characterized using three excitation methods: UV light at 250 nm wavelength, electron beam at 10 kV, and X-rays generated at 100 kV. Regardless of the excitation source, it was found that with increasing particle diameter there is an increase in emitted light. Furthermore, dense particles emit more light than porous particles. These results can be explained by considering the larger surface area to volume ratio of the smallest particles and increased internal surface area of the pores found in the large particles. For the small particles, the additional surface area hosts adsorbates that lead to non-radiative recombination, and in the porous particles, the pore walls can quench fluorescence. This trend is valid across calcination temperatures and is evident when comparing particles from the same calcination temperature

Delivery of mixed-lineage kinase domain-like protein by vapor nanobubble photoporation induces necroptotic-like cell death in tumor cells

Modern molecular medicine demands techniques to efficiently deliver molecules directly into mammalian cells. As proteins are the final mediators of most cellular pathways, efficient intracellular protein delivery techniques are highly desired. In this respect, photoporation is a promising recent technique for the delivery of proteins directly into living cells. Here, we show the possibility to deliver a model saccharide (FD70) and a model protein (FITC-BSA) into murine B16 melanoma cells by using the vapor nanobubble photoporation technique with an efficiency of 62% and 38%, respectively. Next, we delivered the mixed-lineage kinase domain-like (MLKL) protein, the most terminal mediator of necroptosis currently known, and caspase-8 and -3 protein, which are important proteins in the initiation and execution of apoptosis. A significant drop in cell viability with 62%, 71% and 64% cell survival for MLKL, caspase-8 and caspase-3, respectively, was observed. Remarkably, maximal cell death induction was already observed within 1 h after protein delivery. Transduction of purified recombinant MLKL by photoporation resulted in rapid cell death characterized by cell swelling and cell membrane rupture, both hallmarks of necroptosis. As necroptosis has been identified as a type of cell death with immunogenic properties, this is of interest to anti-cancer immunotherapy. On the other hand, transduction of purified recombinant active caspase-3 or -8 into the tumor cells resulted in rapid cell death preceded by membrane blebbing, which is typical for apoptosis. Our results suggest that the type of cell death of tumor cells can be controlled by direct transduction of effector proteins that are involved in the executioner phase of apoptosis or necroptosis

Three-dimensional model study of the Arctic ozone loss in 2002/2003 and comparison with 1999/2000 and 2003/2004

We have used the SLIMCAT 3-D off-line chemical transport model (CTM) to quantify the Arctic chemical ozone loss in the year 2002/2003 and compare it with similar calculations for the winters 1999/2000 and 2003/2004. Recent changes to the CTM have improved the model's ability to reproduce polar chemical and dynamical processes. The updated CTM uses σ-θ as a vertical coordinate which allows it to extend down to the surface. The CTM has a detailed stratospheric chemistry scheme and now includes a simple NAT-based denitrification scheme in the stratosphere. In the model runs presented here the model was forced by ECMWF ERA40 and operational analyses. The model used 24 levels extending from the surface to ~55km and a horizontal resolution of either 7.5° x 7.5° or 2.8° x 2.8°. Two different radiation schemes, MIDRAD and the CCM scheme, were used to diagnose the vertical motion in the stratosphere. Based on tracer observations from balloons and aircraft, the more sophisticated CCM scheme gives a better representation of the vertical transport in this model which includes the troposphere. The higher resolution model generally produces larger chemical O3 depletion, which agrees better with observations. The CTM results show that very early chemical ozone loss occurred in December 2002 due to extremely low temperatures and early chlorine activation in the lower stratosphere. Thus, chemical loss in this winter started earlier than in the other two winters studied here. In 2002/2003 the local polar ozone loss in the lower stratosphere was ~40% before the stratospheric final warming. Larger ozone loss occurred in the cold year 1999/2000 which had a persistently cold and stable vortex during most of the winter. For this winter the current model, at a resolution of 2.8° x 2.8°, can reproduce the observed loss of over 70% locally. In the warm and more disturbed winter 2003/2004 the chemical O3 loss was generally much smaller, except above 620K where large losses occurred due to a period of very low minimum temperatures at these altitudes

Endosomal size and membrane leakiness influence proton sponge-based rupture of endosomal vesicles

In gene therapy, endosomal escape represents a major bottleneck since nanoparticles often remain entrapped inside endosomes and are trafficked toward the lysosomes for degradation. A detailed understanding of the endosomal barrier would be beneficial for developing rational strategies to improve transfection and endosomal escape. By visualizing individual endosomal escape events in live cells, we obtain insight into mechanistic factors that influence proton sponge-based endosomal escape. In a comparative study, we found that HeLa cells treated with JetPEI/pDNA polyplexes have a 3.5-fold increased endosomal escape frequency compared to ARPE-19 cells. We found that endosomal size has a major impact on the escape capacity. The smaller HeLa endosomes are more easily ruptured by the proton sponge effect than the larger ARPE-19 endosomes, a finding supported by a mathematical model based on the underlying physical principles. Still, it remains intriguing that even in the small HeLa endosomes, <10% of the polyplex-containing endosomes show endosomal escape. Further experiments revealed that the membrane of polyplex-containing endosomes becomes leaky to small compounds, preventing effective buildup of osmotic pressure, which in turn prevents endosomal rupture. Analysis of H1299 and A549 cells revealed that endosomal size determines endosomal escape efficiency when cells have comparable membrane leakiness. However, at high levels of membrane leakiness, buildup of osmotic pressure is no longer possible, regardless of endosomal size. Based on our findings that both endosomal size and membrane leakiness have a high impact on proton sponge-based endosomal rupture, we provide important clues toward further improvement of this escape strategy