Tearing Down the Wall: How Transfer-on-Death Real-Estate Deeds Challenge the Inter Vivos/Testamentary Divide

This Article will examine one of the most recent will substitutes, the transfer-on-death (“TOD”) real-estate deed. Nearly half of the states have recognized, through common-law forms or legislation, a mechanism to allow for the transfer of real property on death without using a will, without following the will formalities, and without necessitating probate. This new tool in the estate planner’s toolbox is invaluable: revocable trusts have proven too expensive for decedents of modest means, and wills continue to require formalities that can easily frustrate non-lawyer-drafted estate documents. But the variety of TOD deed rules and mechanisms that the different states have adopted has led to disparity and uncertainty in form and outcome, resulting in litigation and frustration of decedent’s intent. We believe this uncertainty and frustration will continue as even more states adopt the Uniform Real Property Transfer on Death Act (“URPTODA”), which purports to stabilize the law and facilitate testamentary intent. States grappling with this new form interpose significant differences, and lawyers and judges are not all on the same page as to the consequences. One source of confusion is the URPTODA’s provision that TOD deeds are non-testamentary and, at the same time, the Uniform Act provides that the property rights do not transfer until death. Although it is one thing to declare that TOD deeds are non-testamentary even though property rights don’t transfer until death—which in itself goes against centuries of formal legal rules—it is quite another to get all the other legal consequences to fall into place accordingly. For instance, would a state’s anti-lapse statute apply to save a beneficiary designation if the deed is deemed non-testamentary, even though the intent is to have the real property transfer upon death? In our opinion, the TOD deed pushes the juridical binary of inter vivos and testamentary transfers beyond coherence and rationality. The law of will substitutes has already undermined the rationality of maintaining the divide, and in this Article, we will argue that the time has finally come to reject the division between inter vivos and testamentary transfers and seek a rational and holistic set of tools and formalities to gain the benefits of probate avoidance that will substitutes provide with the ease of control and full revocability of wills. Elevating form over functionality, although a characteristic of the common law, inevitably disserves the interests of those who cannot afford lawyers who can easily draft around the sometimes-arcane distinctions between testamentary and inter vivos transfers to gain the benefits of each while avoiding the burdens

Regulation of Globin Gene Expression

Imperial Users onl

Piece of Driftwood, A Riverboat, or A Nazi Collaborator? Finland in World War II

Graduate Three Minute Thesi

The effect of aging and resveratrol supplementation on bone mass and strength in hindlimb suspended male rats

Resveratrol has recently become a popular dietary supplement because of its potential for reducing the effects of aging and various age-related diseases. However, few studies have investigated the role of resveratrol in improving bone loss associated with aging. It has been widely reported that mechanical unloading increases bone loss. The elderly experience a prevalence of reduced mechanical loading due to declining activity levels and increased incidence of bed rest. In rats, hind-limb suspension (HLS) simulates mechanical unloading of bone. Therefore, the objective of this study was to examine the effects of aging and resveratrol supplementation on bone health in HLS and ambulatory (AMB) rats.;Mature (age 6 months) and old (32 months) Fischer Brown Norway male rats were randomly assigned (n=7/group) to HLS or kept ambulatory (AMB) for 14 days and received either 1 ml of trans-resveratrol at a dose of 12.5 mg·kg bw-1·d-1 or deionized water administered by oral gavage. After 14 days, both femurs and tibiae were collected. Bone mineralization was measured by dual energy x-ray absorptiometry (DEXA). Bone calcium (Ca) and phosphorus (P) were determined by inductively coupled plasma spectrophotometry. Bone architecture was determined using micro-computed tomography (muCT). Oxidation was determined by measuring plasma thiobarbituric acid reactive substances (TBARS) by enzyme immunoassay (EIA). Inflammation was determined by measuring C-reactive protein (CRP) by ELIZA.;Results showed that aging increased plasma CRP and reduced trabecular bone (P\u3c0.001). In old AMB rats, resveratrol supplementation increased trabecular thickness (P=0.018), but decreased tibia bone mineral area (P=0.031) and bone mineral content ( P=0.034). In old HLS rats, resveratrol supplementation increased trabecular bone (P\u3c0.001) and reduced oxidation indicated by decreased plasma TBARS (P\u3c0.05) compared to rats not provided resveratrol. In mature HLS rats resveratrol supplementation reduced bone Ca (P=0.018) and P (P=0.024) content. TBARS were increased compared to rats provided no resveratrol. In conclusion resveratrol supplementation attenuated trabecular loss but was not effective at attenuating bone mineral loss associated with aging. In mature HLS rats resveratrol supplementation increased plasma oxidation and reduced bone Ca and P content. Therefore, resveratrol is not recommended as a treatment for age-related bone loss

The Soundtrack of Our Lives: John Williams and the Revitalization of Classical Orchestration in Film Scores

Graduate Creative and Artisti

Torn Between the Creeds of the Devil: The German-Finnish Co-Belligerency in World War II

Graduate Textual or Investigativ

Torn Between the “Creeds of the Devil”: The German-Finnish Co-Belligerency in World War II

In an article for the Sunday Chronicle in June 1937, Winston Churchill described Nazism and Communism as “the creeds of the devil.” Caught between these two ideologies that “are at each other’s throats,” Finland attempted to remain a sovereign nation. This would prove to be virtually impossible after the November 1939 Soviet invasion of Finland. While Joseph Stalin and his advisors “expected [a] triumphal parade,” the dogged resistance of the Finnish Army and people “turned [that parade] into a bloody three-month war.” Furnished in the crucible of conflict, battling for their very existence as a nation, the Winter War united a previously divided people and forged a united Finnish national identity. Reeling from the destructive war, Finnish leaders strove never to be in the same position again. This context is particularly important when studying the motives of Finnish leaders. Convinced that it was their only viable option and provided with an opportunity to regain what they lost, Finnish leaders pragmatically decided to commit to a co-belligerency with Nazi Germany in the fall of 1940. However, this decision must be placed within its immediate context—the decades preceding the outbreak of World War II and the Winter War. The Finnish leaders and citizens failed to understand not only the nature of warfare on the Eastern Front but also the ramifications of allying with a nation like Nazi Germany. Finland became intertwined with a genocidal war on the Eastern Front, and some of its soldiers participated in Nazi atrocities committed against Jews, civilians, and Soviet prisoners of war. The Finnish-German co-belligerency played a significant role in the history of World War II and especially in Finland’s struggle as a newly independent nation navigating the complex geopolitical environment

Cambridge, Trinity College, B.14.3: Arator, "De actibus apostolorum"; Dunstan Acrostic

78. Cambridge, Trinity College, B.14.3 (289) Arator, "De actibus apostolorum"; Dunstan Acrostic [Ker 85, Gneuss 175] HISTORY: A copy of Arator's 6c poem "De Actibus Apostolorum" (NfcKinlay's "C" in Class I of the "coclicum meliorum" (1951: xlii]), written in English Caroline minuscule by several scribes s. x/xi (Keynes 1992: 27). The origin is Christ Church, Canterbury, as shown by the scribe who wrote ff. 22v/5-23r/4 (Bishop's xv; see 1963: 114-16), whose hand appears elsewhere in London, British Library, Royal 6. A. VI (288] (Aldhelm; Gneuss 464), in the marginal gloss in Oxford, BodleianL ibrary, Auct. F. I. 15 [343], pt. i (Boethius; Gneuss 533), and in King Æthelred's charter for Muchelney Abbey (Sawyer 1968: 884). The mark "FF" (above a later shelf-mark, 'Distinctio ii, Gradus xiii') on f. Sr (Keynes 1992: Plate XVI) locates the book at Christ Church in the 12c, James (1903: 506, 25) identifying it as no. 79 in the list of Prior Eastry (1284-1331), "Arator de Actibus apostolorum Petri et Pauli, libri ii." There is an interlinear gloss running throughout the text, and a marginal gloss. In ff. 1-25 a system of syntactical glosses using patterns of dots and letters above words suggests the manuscript may have been used for teaching Latin. The manuscript was given to Trinity College by George Willmer, ca. 1610; his arms are stamped on the binding. On the inside front cover is a cancelled class mark 'R.10.4', current class mark 'B.XIV.3' and a Trinity College bookplate. On first paper flyleaf is, 'B.14.3 | Arator de Acti<bus> | Ap<os>to<lorum> Petri | & | Pauli' in a 19c hand. On the verso of a parchment slip at the beginning of the manuscript, ruled as though for a music stave, is the following, scarcely legible, as transcribed by James: "Ericus Benzelius Suevus contuli hunc librum MS praestantissimum cum impressis. 1700. m. Junio." The annotator "was Bishop ofLinkjoping, and chief Librarian ofUppsala. His projected edition of Ara tor never appeared" Qames 1900-1904: 1.405)