Beyond the Fruit Tree: A Proposal for Revision of the Assignment of Income Doctrine—Caruth Corp. v. United States, 865 F.2d 644 (5th Cir. 1989)

The Supreme Court developed the assignment of income doctrine to solve the question of who the proper taxpayer is under section 61 of the Internal Revenue Code. The question arises when individuals transfer income that rightly belongs to them without declaring the income for federal tax purposes. The assignment doctrine attributes income, for tax purposes, to the earner or practical owner of the income notwithstanding that person\u27s assignment of the income. However, the Supreme Court\u27s development of the doctrine has been inadequate, as exemplified by the recent decision of the Fifth Circuit Court of Appeals in Caruth Corp. v. United State. Caruth demonstrates the improper focus of the traditional doctrine on form rather than substance. The doctrine should be redefined to attribute assigned income to taxpayers based upon who controls and enjoys that income rather than upon the form of the transaction in which the income was transferred

Optimization of a Quantum Cascade Laser Operating in the Terahertz Frequency Range Using a Multiobjective Evolutionary Algorithm

A quantum cascade (QC) laser is a specific type of semiconductor laser that operates through principles of quantum mechanics. In less than a decade QC lasers are already able to outperform previously designed double heterostructure semiconductor lasers. Because there is a genuine lack of compact and coherent devices which can operate in the far-infrared region the motivation exists for designing a terahertz QC laser. A device operating at this frequency is expected to be more efficient and cost effective than currently existing devices. It has potential applications in the fields of spectroscopy, astronomy, medicine and free-space communication as well as applications to near-space radar and chemical/biological detection. The overarching goal of this research was to find QC laser parameter combinations which can be used to fabricate viable structures. To ensure operation in the THz region the device must conform to the extremely small energy level spacing range from ~10-15 meV. The time and expense of the design and production process is prohibitive, so an alternative to fabrication was necessary. To accomplish this goal a model of a QC laser, developed at Worchester Polytechnic Institute with sponsorship from the Air Force Research Laboratory Sensors Directorate, and the General Multiobjective Parallel Genetic Algorithm (GenMOP), developed at the Air Force Institute of Technology, were integrated to form a computer simulation which stochastically searches for feasible solutions

Improving Healthcare Readiness to Respond to Human Trafficking: A Case Study

The purpose of this qualitative case study was to assess the readiness of a Department of Emergency Medicine (ED) to respond to human trafficking (HT), using an adapted Transtheoretical Model’s Stage of Change Model as a guide. Content analysis allowed for an assessment of 13 system-wide policies and procedures and 25 hours of on-site observations of patient data collection processes and clinical practices during intake, triage, and the medical screening evaluation at three ED sites. Thematic analysis identified five readiness themes based on semi-structured interviews with 22 healthcare personnel from four ED sties. Results indicated that system-wide policies and procedures and patient data collection processes were at the precontemplative level of change across ED sites, meaning low levels of readiness to respond to HT. Clinical practice findings showed participants used their knowledge and expertise with other vulnerable patient populations to raise concerns about possible trafficked individuals seeking medical care, placing clinical practices at the contemplative level of change. Based on findings, recommendations to increase the ED’s readiness to respond to HT included: mandating HT training for all ED personnel to enhance awareness, incorporating HT into current policies and procedures for vulnerable patient populations as well as creating a HT protocol that addresses a procedural work flow, enhancing patient data collection to include HT warning signs, identifying a consistent area to record suspicions in patients’ medical records, and making community referral information readily available for staff. Future research with other EDs can apply the adapted TTM framework to determine the efficacy of this assessment model to assess HT readiness

The Perceptions of Division Ill Senior Woman Administrators on Sexual Discrimination in Intercollegiate Athletics

This study examined the perceptions of Division Ill Senior Woman Administrators (SWAs) on three forms of sexual discrimination in intercollegiate athletic departments: (a) gender inequity and overt discrimination, (b) sexual harassment, and (c) artificial barriers in employment. The effect of sexual discrimination on the employment of women in the athletic profession was also examined. A Likert scale survey was sent to randomly selected SWAs at NCAA Division Ill member institutions. Descriptive statistics revealed that Division Ill SWAs do not perceive sexual discrimination to exist in a global form in intercollegiate athletics. However, a perception of sexual discrimination was found in the subgroups of overt discrimination and artificial barriers in employment. Globally, sexual discrimination was not perceived to have an effect on the decline of, and low percentage of females working in intercollegiate athletics

An Examination of Behaviors and Attitudes toward Food Based on the Self-Reported Desire to Lose Weight: A Comparison of Two Groups in the United States and Italy

This research uses a survey instrument in the United States and Italy to examine the relationship between consumers’ demographics, attitudes, and behaviors toward food purchasing and their self-described desire to lose weight. Approximately two-thirds of consumers in the United States and slightly over half of consumers in Italy indicated a desire to lose weight. Married consumers with children in the household in both countries are more likely to desire to lose weight. Furthermore, consumers from both countries who desire to lose weight were more likely to agree that “the main meal of the day is the most important time of the day for my household.†Although the main meal of the day is more important to consumers from both countries who desire to lose weight, consumers in the United States who desire to lose weight were more likely to indicate that every member of their families eat the main meal together. Consumers in Italy who desire to lose weight were less likely to indicate that every member of their families eat the main meal together. The self-described overweight consumers in both countries enjoy cooking and have sufficient food for their families. However, the overweight consumer in the United States is often too busy to cook. This research finds no difference in the number of meals eaten away from home in a typical week between those in each country who desire to lose weight and those who do not. Furthermore, in the United States the sources of foods eaten away from home, such as fast food, are not related to the importance to the consumer of weight loss.Food Consumption/Nutrition/Food Safety, Health Economics and Policy,

Conflict, Leadership, and Performance: What Virtual Team Members Need to Know

Conflict and leadership are both individually well-studied elements of group development. In this paper we seek to understand how leadership and conflict coexist within a team’s development and what the temporal context is within which they emerge for higher- versus lower-performing teams. In order to investigate this question we collected survey data, message postings and performance scores for 22 virtual teams over an 11-week period. Our results suggest that high-performing teams experience less relational conflict, engage in more task leadership, and respond more promptly to conflict with appropriate leadership behaviors. We situate these findings in the context of what virtual team members need to know

A Comparison of Two Plyometric Training Techniques

The purpose of this study was to investigate two different plyometric training techniques for increasing vertical jumping ability. Twenty-four female high school volleyball players were matched for height and weight and distributed equally among three groups. Each subject performed a vertical jump test, Margaria power test, Wingate bicycle test, and an isokinetic leg strength test prior to and following six weeks of training. Plyometric training significantly (p<.05) improved vertical jumping ability and some indices of leg strength and power. Weighted plyometrics did not enhance performance more than plyometrics alone. These data support the view that plyometric training with or without added weights enhances vertical jumping and leg power

Fitting Graphical DSS to Task Characteristics

Previous research has found the use of graphical Decision Support Systems (DSS) to be more effective than tabular DSS in some decision situations, but not in others [8, 9]. This paper presents the results of two laboratory experiments testing the hypothesis that the features provided by graphical DSS may best fit some tasks, while those of tabular DSS best fit other tasks. The first experiment, which examined decision outcomes, found that a tabular DSS better fit a less complex task, while a graphical DSS better fit a more complex task with high information load in which decision makers needed to understand relationships among data elements. The second experiment, which examined decision processes, found that decision makers using graphical DSS tended to use less information in making their decisions than those using tabular DSS

Task-Technology Fit and Culture: Perceptions of and Media Feature Preferences for The Task of Delivering Bad Nwes

Task-technology fit (TTF) suggests that what drives technology utilizations is individuals’ subjective evaluations of fit. The technology aspect that gives rise to task-technology fit has received extensive attention, and researchers recently called for more attention to the task aspect. In this paper, we examine how culture may affect the task aspect of TTF, consequently leading to differences in subjective evaluations of fit and ultimately technology utilizations. Moreover, we distinguish the two mechanisms via which culture may affect the task aspect of task-technology fit, i.e., task perception and task response. Focusing on the task of delivering bad news, we examine cultural differences (China vs. Non-China) in the perception of and responses to (in terms of media feature preferences) the task of delivering bad news. Data was collected using surveys from clients of a multinational public relations company. Results show that there was no difference in task perception for delivering bad news between Chinese and Non-Chinese participants, marginally supported difference in the preferences for rehearsability, and no difference in the preference for symbol sets