FEDERAL TAXATION: PERSPECTIVE DURING THE FIFTH DECADE

Since the enactment of the income tax provisions of the Tariff Act of October 3, 1913 forty years have elapsed within which we have seen a profound change in the revenue system of our federal government, the growth of a great new branch of public law, the development of a highly specialized field of legal practice and the publication in legal periodicals of innumerable articles on the subject of taxation. Tax men can, with great pride, point out that technical proficiency has done an amazing job of keeping pace with the rapid expansion of the system from the utilization of the latest punch card accounting machines by the Internal Revenue Service to an orderly procedure for the hearing of thousands of taxpayers\u27 protests before a tribunal which did not exist prior to 1924, to the creation of professional journals dealing exclusively with taxation. There is no reason to believe that technological progress will falter in the next decade regardless of the course federal taxation may take. The course it will take is the real matter of concern and is in large measure controlled by the perspective of those individuals who formulate tax policies, the members of the congressional committees, the judges, the policy makers within the Treasury Department, and the experts who influence those officials, the accountants, the economists, and the members of the tax bar. It is with the subject of perspective that this article is concerned, and the thesis of the following comments is that the perspective must be sweeping; that those individuals concerned. with tax policy should consciously acknowledge that taxation is an integral part of the legal and economic fabric of the country and that changes in tax policy must be correlated with changes in basic economic and legal philosophy

TAXATION-FEDERAL GIFT TAX-LIFE INSURANCE POLICIES

On December 19, 1930 the petitioner created two trusts, placing in the first five $100,000 life insurance policies on the life of her husband, and in the second, securities, the income from which was to pay premiums on the policies, excess if any to be paid to the petitioner; after the death of her husband the whole of the income from the securities was to be paid to her for life. On death of the husband the proceeds of the life insurance policies were to be used to provide life estates for four named beneficiaries followed by remainders over; and on the death of the petitioner the securities in the second trust were to be added to the proceeds of the policies, thus augmenting the trust estates. The petitioner reserves the exclusive right to revoke the trusts during the lifetime of her husband, and after his death the right to repossess herself of any amount up to 50 per cent of the corpus of the securities trust. The husband of the petitioner died . March 10, 1939, but she reported no taxable gifts for that year. The commissioner assessed a deficiency on$503,314.15, the face value of the policies plus post mortem dividends. Petitioner appealed the assessment to the Tax Court. In that court she, first contended that she had made no gift in 1939, but the court overruled her on the basis of Burnet v. Guggenheim. She then contended that the value of the gift is the value of property which passes from the donor and not the value of the property receivable by the donee. The Tax Court, however, found the value of the gift to be $503,314.15. Petitioner appealed, disputing only the finding on the issue of valuation. Held, affirmed. Goodman v. Commissioner of Internal Revenue, (C.C.A. 2d, 1946) 156 F. (2d) 218

TAXATION-EXCESS PROFITS-GENERAL RELIEF UNDER SECTION 722 I. R. C

Even the most casual observer of modern business practices will accede to the general proposition that the most accurate reflection of market value for many commodities can be found in documentary sources. This is particularly true of those commodities of an homogeneous character which are sold in well-organized markets characterized by price uniformity and free access to price information. Of them, it may well be said that no more satisfactory evidence of market value than the newspaper market reports can be found, barring the possibility of personal observation of the board at the market itself. However, the average businessman will also rely on documentary indications of market value, such as price lists and catalogs, when dealing with articles of manufacture which, because of style variations or other peculiar characteristics, are not readily interchangeable with other articles of like design and manufacture. In addition, the business world will attach great significance to the influence of the document on the market in determining the credibility of price lists and similar documents where it appears that prices may be influenced by monopolistic control. It is proposed to examine herein the competency of all such documents as evidence of market value and to inquire as to the circumstances which control their admissibility

Yersinia pestis Lineages in Mongolia

BACKGROUND: Whole genome sequencing allowed the development of a number of high resolution sequence based typing tools for Yersinia (Y.) pestis. The application of these methods on isolates from most known foci worldwide and in particular from China and the Former Soviet Union has dramatically improved our understanding of the population structure of this species. In the current view, Y. pestis including the non or moderate human pathogen Y. pestis subspecies microtus emerged from Yersinia pseudotuberculosis about 2,600 to 28,600 years ago in central Asia. The majority of central Asia natural foci have been investigated. However these investigations included only few strains from Mongolia. METHODOLOGY/PRINCIPAL FINDINGS: Clustered Regularly Interspaced Short Prokaryotic Repeats (CRISPR) analysis and Multiple-locus variable number of tandem repeats (VNTR) analysis (MLVA) with 25 loci was performed on 100 Y. pestis strains, isolated from 37 sampling areas in Mongolia. The resulting data were compared with previously published data from more than 500 plague strains, 130 of which had also been previously genotyped by single nucleotide polymorphism (SNP) analysis. The comparison revealed six main clusters including the three microtus biovars Ulegeica, Altaica, and Xilingolensis. The largest cluster comprises 78 isolates, with unique and new genotypes seen so far in Mongolia only. Typing of selected isolates by key SNPs was used to robustly assign the corresponding clusters to previously defined SNP branches. CONCLUSIONS/SIGNIFICANCE: We show that Mongolia hosts the most recent microtus clade (Ulegeica). Interestingly no representatives of the ancestral Y. pestis subspecies pestis nodes previously identified in North-western China were identified in this study. This observation suggests that the subsequent evolution steps within Y. pestis pestis did not occur in Mongolia. Rather, Mongolia was most likely re-colonized by more recent clades coming back from China contemporary of the black death pandemic, or more recently in the past 600 years

Depression prevalence using the HADS-D compared to SCID major depression classification:An individual participant data meta-analysis

Objectives: Validated diagnostic interviews are required to classify depression status and estimate prevalence of disorder, but screening tools are often used instead. We used individual participant data meta-analysis to compare prevalence based on standard Hospital Anxiety and Depression Scale – depression subscale (HADS-D) cutoffs of ≥8 and ≥11 versus Structured Clinical Interview for DSM (SCID) major depression and determined if an alternative HADS-D cutoff could more accurately estimate prevalence. Methods: We searched Medline, Medline In-Process & Other Non-Indexed Citations via Ovid, PsycINFO, and Web of Science (inception-July 11, 2016) for studies comparing HADS-D scores to SCID major depression status. Pooled prevalence and pooled differences in prevalence for HADS-D cutoffs versus SCID major depression were estimated. Results: 6005 participants (689 SCID major depression cases) from 41 primary studies were included. Pooled prevalence was 24.5% (95% Confidence Interval (CI): 20.5%, 29.0%) for HADS-D ≥8, 10.7% (95% CI: 8.3%, 13.8%) for HADS-D ≥11, and 11.6% (95% CI: 9.2%, 14.6%) for SCID major depression. HADS-D ≥11 was closest to SCID major depression prevalence, but the 95% prediction interval for the difference that could be expected for HADS-D ≥11 versus SCID in a new study was −21.1% to 19.5%. Conclusions: HADS-D ≥8 substantially overestimates depression prevalence. Of all possible cutoff thresholds, HADS-D ≥11 was closest to the SCID, but there was substantial heterogeneity in the difference between HADS-D ≥11 and SCID-based estimates. HADS-D should not be used as a substitute for a validated diagnostic interview.This study was funded by the Canadian Institutes of Health Research (CIHR, KRS-144045 & PCG 155468). Ms. Neupane was supported by a G.R. Caverhill Fellowship from the Faculty of Medicine, McGill University. Drs. Levis and Wu were supported by Fonds de recherche du Québec - Santé (FRQS) Postdoctoral Training Fellowships. Mr. Bhandari was supported by a studentship from the Research Institute of the McGill University Health Centre. Ms. Rice was supported by a Vanier Canada Graduate Scholarship. Dr. Patten was supported by a Senior Health Scholar award from Alberta Innovates, Health Solutions. The primary study by Scott et al. was supported by the Cumming School of Medicine and Alberta Health Services through the Calgary Health Trust, and funding from the Hotchkiss Brain Institute. The primary study by Amoozegar et al. was supported by the Alberta Health Services, the University of Calgary Faculty of Medicine, and the Hotchkiss Brain Institute. The primary study by Cheung et al. was supported by the Waikato Clinical School, University of Auckland, the Waikato Medical Research Foundation and the Waikato Respiratory Research Fund. The primary study by Cukor et al. was supported in part by a Promoting Psychological Research and Training on Health-Disparities Issues at Ethnic Minority Serving Institutions Grants (ProDIGs) awarded to Dr. Cukor from the American Psychological Association. The primary study by De Souza et al. was supported by Birmingham and Solihull Mental Health Foundation Trust. The primary study by Honarmand et al. was supported by a grant from the Multiple Sclerosis Society of Canada. The primary study by Fischer et al. was supported as part of the RECODEHF study by the German Federal Ministry of Education and Research (01GY1150). The primary study by Gagnon et al. was supported by the Drummond Foundation and the Department of Psychiatry, University Health Network. The primary study by Akechi et al. was supported in part by a Grant-in-Aid for Cancer Research (11−2) from the Japanese Ministry of Health, Labour and Welfare and a Grant-in-Aid for Young Scientists (B) from the Japanese Ministry of Education, Culture, Sports, Science and Technology. The primary study by Kugaya et al. was supported in part by a Grant-in-Aid for Cancer Research (9–31) and the Second-Term Comprehensive 10-year Strategy for Cancer Control from the Japanese Ministry of Health, Labour and Welfare. The primary study Ryan et al. was supported by the Irish Cancer Society (Grant CRP08GAL). The primary study by Keller et al. was supported by the Medical Faculty of the University of Heidelberg (grant no. 175/2000). The primary study by Love et al. (2004) was supported by the Kathleen Cuningham Foundation (National Breast Cancer Foundation), the Cancer Council of Victoria and the National Health and Medical Research Council. The primary study by Love et al. (2002) was supported by a grant from the Bethlehem Griffiths Research Foundation. The primary study by Löwe et al. was supported by the medical faculty of the University of Heidelberg, Germany (Project 121/2000). The primary study by Navines et al. was supported in part by the Spanish grants from the Fondo de Investigación en Salud, Instituto de Salud Carlos III (EO PI08/90869 and PSIGEN-VHC Study: FIS-E08/00268) and the support of FEDER (one way to make Europe). The primary study by O'Rourke et al. was supported by the Scottish Home and Health Department, Stroke Association, and Medical Research Council. The primary study by Sanchez-Gistau et al. was supported by a grant from the Ministry of Health of Spain (PI040418) and in part by Catalonia Government, DURSI 2009SGR1119. The primary study by Gould et al. was supported by the Transport Accident Commission Grant. The primary study by Rooney et al. was supported by the NHS Lothian Neuro-Oncology Endowment Fund. The primary study by Schwarzbold et al. was supported by PRONEX Program (NENASC Project) and PPSUS Program of Fundaçao de Amparo a esquisa e Inovacao do Estado de Santa Catarina (FAPESC) and the National Science and Technology Institute for Translational Medicine (INCT-TM). The primary study by Simard et al. was supported by IDEA grants from the Canadian Prostate Cancer Research Initiative and the Canadian Breast Cancer Research Alliance, as well as a studentship from the Canadian Institutes of Health Research. The primary study by Singer et al. (2009) was supported by a grant from the German Federal Ministry for Education and Research (no. 01ZZ0106). The primary study by Singer et al. (2008) was supported by grants from the German Federal Ministry for Education and Research (# 7DZAIQTX) and of the University of Leipzig (# formel. 1–57). The primary study by Meyer et al. was supported by the Federal Ministry of Education and Research (BMBF). The primary study by Stone et al. was supported by the Medical Research Council, UK and Chest Heart and Stroke, Scotland. The primary study by Turner et al. was supported by a bequest from Jennie Thomas through Hunter Medical Research Institute. The primary study by Walterfang et al. was supported by Melbourne Health. Drs. Benedetti and Thombs were supported by FRQS researcher salary awards. No other authors reported funding for primary studies or for their work on this study. No funder had any role in the design and conduct of the study; collection, management, analysis, and interpretation of the data; preparation, review, or approval of the manuscript; and decision to submit the manuscript for publication