Income Tax Aspects of Liquidation of Partnership Interest of Retiring or Deceased Partner

Income Tax Aspects of Liquidation of Partnership Interest of Retiring or Deceased Partne

CONSTITUTIONAL LAW - LABOR LAW - RECENT RAMIFICATIONS OF THE APPLICATION OF FREE SPEECH DOCTRINES TO THE PROTECTION OF PICKETING

When the United States Supreme Court declared that peaceful picketing was protected by the constitutional guaranty of free speech, it raised the interesting question how the doctrines shielding the traditional modes of free speech were to be adapted to the preservation of picketing. A smooth cloaking of the right to picket with the sanctity of a constitutionally protected civil liberty is complicated by various factors such as the ease with which picketing may lead to violence, the elements of economic coercion inherent in even peaceful picketing, and the detrimental repercussions upon strangers to the controversy. As a result the clash between constitutional right and state police power usually is more severe when freedom of speech takes the form of a picket line than when it is exercised through other mediums

DAMAGES - EFFECT OF DEFENDANT\u27S TENDER OF SPECIFIC RESTITUTION UPON PLAINTIFF\u27S ACTION TO RECOVER THE VALUE OF PROPERTY

A person who has appropriated the land or chattels of another may prefer to return the subject matter rather than be held liable for its money equivalent in a law suit brought by the rightful owner. Whether the appropriator will improve his position by tendering specific restitution presents an interesting question. Because of the numerous remedies at the owner\u27s disposal, it is impossible to formulate a single, concise answer

Bootstraps and Capital Gain--A Participant\u27s View of \u3cem\u3eCommissioner v. Clay Brown\u3c/em\u3e

A closely held corporation may be sold in a variety of ways. At one end of the spectrum is an all-cash sale. In such a transaction, the seller receives the purchase price and has no further concern with the economic well-being of the business. The difficulty with this method, of course, is finding a purchaser with sufficient cash who is willing to pay a fair price. At the other end of the spectrum is a full-fledged bootstrap sale, where there is no down payment other than from the underlying assets of the sold corporation, and the purchaser\u27s obligation to pay the purchase price over a period of years is dependent upon income generated by the underlying corporate assets and upon the assets themselves. Because of this dependency, a bootstrap seller remains vitally interested in the economic well-being of the corporation until the purchase price is fully paid. Between these two extremes are sales where some down payment is made from independent sources, and the purchaser assumes personal liability for all or a portion of the purchase price. The significance of the· purchaser\u27s assumption of personal liability naturally depends upon his financial affluence

Letters between H. H. Kinsey and W. J. Kerr

Letters concerning the cost of a course at Utah Agricultural College

Atomic Resonance and Scattering

Contains reports on eight research projects.National Science Foundation (Grant PHY77-09155)Joint Services Electronics Program (Contract DAAG29-78-C-0020)U. S. Department of Energy (Grant EG-77-S-02-4370)National Science Foundation (Grant DMR 77-10084)National Aeronautics and Space Administration (Grant NSG-1551)U. S. Air Force - Office of Scientific Research (Grant AFOSR-76-2972)National Science Foundation (Grant CHE76-81750

Improved Mitochondrial Function with Diet-Induced Increase in Either Docosahexaenoic Acid or Arachidonic Acid in Membrane Phospholipids

Mitochondria can depolarize and trigger cell death through the opening of the mitochondrial permeability transition pore (MPTP). We recently showed that an increase in the long chain n3 polyunsaturated fatty acids (PUFA) docosahexaenoic acid (DHA; 22:6n3) and depletion of the n6 PUFA arachidonic acid (ARA; 20:4n6) in mitochondrial membranes is associated with a greater Ca2+ load required to induce MPTP opening. Here we manipulated mitochondrial phospholipid composition by supplementing the diet with DHA, ARA or combined DHA+ARA in rats for 10 weeks. There were no effects on cardiac function, or respiration of isolated mitochondria. Analysis of mitochondrial phospholipids showed DHA supplementation increased DHA and displaced ARA in mitochondrial membranes, while supplementation with ARA or DHA+ARA increased ARA and depleted linoleic acid (18:2n6). Phospholipid analysis revealed a similar pattern, particularly in cardiolipin. Tetralinoleoyl cardiolipin was depleted by 80% with ARA or DHA+ARA supplementation, with linoleic acid side chains replaced by ARA. Both the DHA and ARA groups had delayed Ca2+-induced MPTP opening, but the DHA+ARA group was similar to the control diet. In conclusion, alterations in mitochondria membrane phospholipid fatty acid composition caused by dietary DHA or ARA was associated with a greater cumulative Ca2+ load required to induced MPTP opening. Further, high levels of tetralinoleoyl cardiolipin were not essential for normal mitochondrial function if replaced with very-long chain n3 or n6 PUFAs

Think Again – Supplying War: Reappraising Military Logistics and Its Centrality to Strategy and War

This article argues that logistics constrains strategic opportunity while itself being heavily circumscribed by strategic and operational planning. With the academic literature all but ignoring the centrality of logistics to strategy and war, this article argues for a reappraisal of the critical role of military logistics, and posits that the study and conduct of war and strategy are incomplete at best or false at worst when they ignore this crucial component of the art of war. The article conceptualises the logistics–strategy nexus in a novel way, explores its contemporary manifestation in an age of uncertainty, and applies it to a detailed case study of UK operations in Iraq and Afghanistan since 2001

Evaluation of individual and ensemble probabilistic forecasts of COVID-19 mortality in the United States

Short-term probabilistic forecasts of the trajectory of the COVID-19 pandemic in the United States have served as a visible and important communication channel between the scientific modeling community and both the general public and decision-makers. Forecasting models provide specific, quantitative, and evaluable predictions that inform short-term decisions such as healthcare staffing needs, school closures, and allocation of medical supplies. Starting in April 2020, the US COVID-19 Forecast Hub (https://covid19forecasthub.org/) collected, disseminated, and synthesized tens of millions of specific predictions from more than 90 different academic, industry, and independent research groups. A multimodel ensemble forecast that combined predictions from dozens of groups every week provided the most consistently accurate probabilistic forecasts of incident deaths due to COVID-19 at the state and national level from April 2020 through October 2021. The performance of 27 individual models that submitted complete forecasts of COVID-19 deaths consistently throughout this year showed high variability in forecast skill across time, geospatial units, and forecast horizons. Two-thirds of the models evaluated showed better accuracy than a naïve baseline model. Forecast accuracy degraded as models made predictions further into the future, with probabilistic error at a 20-wk horizon three to five times larger than when predicting at a 1-wk horizon. This project underscores the role that collaboration and active coordination between governmental public-health agencies, academic modeling teams, and industry partners can play in developing modern modeling capabilities to support local, state, and federal response to outbreaks

The United States COVID-19 Forecast Hub dataset

Academic researchers, government agencies, industry groups, and individuals have produced forecasts at an unprecedented scale during the COVID-19 pandemic. To leverage these forecasts, the United States Centers for Disease Control and Prevention (CDC) partnered with an academic research lab at the University of Massachusetts Amherst to create the US COVID-19 Forecast Hub. Launched in April 2020, the Forecast Hub is a dataset with point and probabilistic forecasts of incident cases, incident hospitalizations, incident deaths, and cumulative deaths due to COVID-19 at county, state, and national, levels in the United States. Included forecasts represent a variety of modeling approaches, data sources, and assumptions regarding the spread of COVID-19. The goal of this dataset is to establish a standardized and comparable set of short-term forecasts from modeling teams. These data can be used to develop ensemble models, communicate forecasts to the public, create visualizations, compare models, and inform policies regarding COVID-19 mitigation. These open-source data are available via download from GitHub, through an online API, and through R packages