CONFLICT OF LAWS-WRONGFUL DEATH-SUIT BY FOREIGN ADMINISTRATION

Plaintiff, an administrator appointed by an Illinois probate court, brought suit in Michigan under the Indiana death act1 to recover for the wrongful death of decedent which resulted from an accident occurring in Indiana. The trial court sustained defendant\u27s motion to dismiss on the ground that plaintiff had no standing to sue in a Michigan court. Held, reversed. The rule barring actions brought by foreign administrators does not apply to suits brought under the usual type of wrongful death act. Howard v. Pulver, (Mich. 1951) 45 N.W. (2d) 530

TAXATION-INCOME TAX-TAXABILITY OF PAYMENTS MADE TO WIDOWS OF DECEASED EMPLOYEES

Payments were made by an employer to the widow of a deceased employee in consideration of services rendered by the employee. Held, the payments were includible in the widow\u27s gross income for federal income tax purposes. I.T. 4027, Int. Rev. Bul., Oct. 16, 1950, 2, 505 CCH ¶6208

Neuromodulation of the failing heart: Lost in translation?

SummarySympathovagal imbalance contributes to progressive worsening of heart failure (HF) and is associated with untoward clinical outcomes. Based on compelling pre-clinical studies that supported the role of autonomic modulation in HF models, a series of clinical studies were initiated using spinal cord stimulation, vagus nerve stimulation, and baroreceptor activation therapy in patients with HF with a reduced ejection fraction. Whereas the phase II studies with baroreceptor activation therapy remain encouraging, the larger clinical studies with spinal cord stimulation and vagus nerve stimulation have yielded disappointing results. Here we will focus on the pre-clinical studies that supported the role of neuromodulation in the failing heart, as well provide a critical review of the recent clinical trials that have sought to modulate autonomic tone in HF patients. This review will conclude with an analysis of some of the difficulties in translating device-based modulation of the autonomic nervous system from pre-clinical models into successful clinical trials, as well as provide suggestions for how to move the field of neuromodulation forward

TAXATION-FEDERAL GIFT TAX-TRANSFERS MADE PURSUANT TO POSTNUPTIAL SEPARATION AGREEMENTS

Taxpayer and her husband entered into a property settlement whereby she agreed to make certain payments to him in return for his promise to relinquish all marital rights in her property. The agreement was not to become operative unless a divorce decree was entered in a then pending action, but it was further provided that the covenants in this agreement shall survive any decree of divorce which may be entered. The subsequent divorce decree approved the agreement and directed performance of its provisions. The Tax Court, which expunged the gift tax deficiency assessed by the Commissioner, was reversed by the Court of Appeals for the Second Circuit, which held the payments subject to the gift tax. On review under a writ of certiorari, held, reversed. The transfers were not founded upon a promise or agreement and therefore they need not meet the requirements of an adequate and full consideration in money or money\u27s worth. Four justices dissented. Harris v. Commissioner of Internal Revenue, 340 U.S. 106, 71 S.Ct. 181 (1950)

FUTURE INTERESTS-SUSPENSION OF POWER OF ALIENATION-EFFECT OF TRUSTEE\u27S POWER TO SELL AND REINVEST

Testatrix\u27 will provided that the residue of her estate was to be held in trust for the benefit of her great-nephews and great-nieces. The income from the trust estate was to be paid to them each year and, when the youngest attained the age of fifty, the corpus was to be divided equally among them. Testatrix left two nephews surviving her. Held, the disposition was valid. There was an implied power in the trustee to sell and reinvest the trust corpus, and therefore, the trust did not violate the statutory prohibition against suspension of the absolute power of alienation. In re Walker\u27s Will, (Wis. 1950) 45 N.W. (2d) 94

COVID-19 clinical trials: A primer for the cardiovascular and cardio-oncology communities

The coronavirus disease-2019 (COVID-19) pandemic has resulted in a proliferation of clinical trials designed to slow the spread of severe acute respiratory syndrome-coronavirus-2 (SARS-CoV-2). Many therapeutic agents that are being used to treat patients with COVID-19 are repurposed treatments for influenza, Ebola, or for malaria that were developed decades ago and are unlikely to be familiar to the cardiovascular and cardio-oncology communities. Here, we provide a foundation for cardiovascular and cardio-oncology physicians on the front line providing care to patients with COVID-19, so that they may better understand the emerging cardiovascular epidemiology and the biological rationale for the clinical trials that are ongoing for the treatment of patients with COVID-19

CONFLICT OF LAWS-DEATH BY WRONGFUL ACT-RECOVERY UNDER FOREIGN STATUTE

A was killed in an automobile accident occurring in Illinois. Alleging that defendant wrongfully caused A\u27s death, A\u27s administrator sought recovery in Wisconsin, basing his claim on the Illinois death act. The trial court granted defendant\u27s motion for summary judgment. Held, affirmed, two justices dissenting. The Wisconsin death act allows recovery of damages for wrongful death provided, that such action shall be brought for a death caused in this state. It follows that maintenance of an action for a death caused in a sister state is against the public policy of Wisconsin. Hughes v. Fetter, 257 Wis. 35, 42 N.W. (2d) 452 (1950)