The Partnership: Preserving Capital Gains on Real Estate Investments

This paper considers the use of partnerships as an effective tool for preserving capital gains on real estate investments. For tax purposes, the Internal Revenue Service generally treats a limited liability company as a partnership. This form of organization is widely used for real estate investments, and by taking a few simple precautions an LLC may ensure that any gain on its investments in undeveloped real property will be treated as capital gains. Such treatment may reduce the LLC’s tax costs substantially. The Fifth Circuit developed a framework that has proven invaluable for analyzing the activity of the LLC to determine whether it will be afforded capital gains status. This paper spends a considerable amount of time analyzing that framework as well as exploring examples of how the courts have applied this framework. Additionally, this paper discusses choice of entity concerns for investors and briefly analyzes the life cycle of a typical real estate investment partnership

Observing complete gravitational wave signals from dynamical capture binaries

We assess the detectability of the gravitational wave signals from highly eccentric compact binaries. We use a simple model for the inspiral, merger, and ringdown of these systems. The model is based on mapping the binary to an effective single black hole system described by a Kerr metric, thereby including certain relativistic effects such as zoom-whirl-type behavior. The resultant geodesics source quadrupolar radiation and, in turn, are evolved under its dissipative effects. At the light ring, we attach a merger model that was previously developed for quasicircular mergers but also performs well for eccentric mergers with little modification. We apply this model to determine the detectability of these sources for initial, Enhanced, and Advanced LIGO across the parameter space of nonspinning close capture compact binaries. We conclude that, should these systems exist in nature, the vast majority will be missed by conventional burst searches or by quasicircular waveform templates in the advanced detector era. Other methods, such as eccentric templates or, more practically, a stacked excess power search, must be developed to avoid losing these sources. These systems would also have been missed frequently in the initial LIGO data analysis. Thus, previous null coincidence results with detected gamma-ray bursts cannot exclude the possibility of coincident gravitational wave signals from eccentric binaries.Comment: 18 pages, 18 figures; revised to match accepted version, PRD in pres

Accurate and efficient waveforms for compact binaries on eccentric orbits

Compact binaries that emit gravitational waves in the sensitivity band of ground-based detectors can have non-negligible eccentricities just prior to merger, depending on the formation scenario. We develop a purely analytic, frequency-domain model for gravitational waves emitted by compact binaries on orbits with small eccentricity, which reduces to the quasi-circular post-Newtonian approximant TaylorF2 at zero eccentricity and to the post-circular approximation of Yunes et al. (2009) at small eccentricity. Our model uses a spectral approximation to the (post-Newtonian) Kepler problem to model the orbital phase as a function of frequency, accounting for eccentricity effects up to ${\cal{O}}(e^8)$ at each post-Newtonian order. Our approach accurately reproduces an alternative time-domain eccentric waveform model for eccentricities $e\in [0, 0.4]$ and binaries with total mass less than 12 solar masses. As an application, we evaluate the signal amplitude that eccentric binaries produce in different networks of existing and forthcoming gravitational waves detectors. Assuming a population of eccentric systems containing black holes and neutron stars that is uniformly distributed in co-moving volume, we estimate that second generation detectors like Advanced LIGO could detect approximately 0.1-10 events per year out to redshift $z\sim 0.2$, while an array of Einstein Telescope detectors could detect hundreds of events per year to redshift $z \sim 2.3$.Comment: 12 pages, 6 figures, 1 appendix. Submitted to Phys. Rev. D. v2: affiliations updated, one reference corrected. Accepted to Phys. Rev.

Development of a questionnaire to measure perceived support during pregnancy and its relation to coping strategies and outcome

There is a considerable body of research examining the effects of social support factors, socioeconomic status (SES) and demographics on pregnancy outcome. However, there has been little research examining the effects of perceptions of social support on pregnancy outcome. The initial studies of this thesis examined the relation of scores on a Support in Pregnancy Questionnaire (SPQ) to pregnancy outcomes (n=68). It was found that the level of perceived support predicted lower infant birthweight and higher rates of obstetric complications (methodological issues of the complication measure are discussed). Furthermore, a small group of women who scored negatively on the questionnaire and received non-directive counselling were comparable to controls who had adequate levels of support. [Continues.

Looking for Irish America in the Memoirs of Mary McCarthy

This is the author accepted manuscript. The final version is available from Taylor & Francis via the DOI in this recor

Disease activity flares and pain flares in an early rheumatoid arthritis inception cohort; characteristics, antecedents and sequelae

© 2019 The Author(s). This article is distributed under the terms of the Creative Commons Attribution 4.0 International License (http://creativecommons.org/licenses/by/4.0/), which permits unrestricted use, distribution, and reproduction in any medium, provided you give appropriate credit to the original author(s) and the source, provide a link to the Creative Commons license, and indicate if changes were made. The Creative Commons Public Domain Dedication waiver (http://creativecommons.org/publicdomain/zero/1.0/) applies to the data made available in this article, unless otherwise stated.Background: RA flares are common and disabling. They are described in terms of worsening inflammation but pain and inflammation are often discordant. To inform treatment decisions, we investigated whether inflammatory and pain flares are discrete entities. Methods: People from the Early RA Network (ERAN) cohort were assessed annually up to 11 years after presentation (n = 719, 3703 person-years of follow up). Flare events were defined in 2 different ways that were analysed in parallel; DAS28 or Pain Flares. DAS28 Flares satisfied OMERACT flare criteria of increases in DAS28 since the previous assessment (≥1.2 points if active RA or ≥ 0.6 points if inactive RA). A ≥ 4.8-point worsening of SF36-Bodily Pain score defined Pain Flares. The first documented episode of each of DAS28 and Pain Flare in each person was analysed. Subgroups within DAS28 and Pain Flares were determined using Latent Class Analysis. Clinical course was compared between flare subgroups. Results: DAS28 (45%) and Pain Flares (52%) were each common but usually discordant, with 60% of participants in DAS28 Flare not concurrently in Pain Flare, and 64% of those in Pain Flare not concurrently in DAS28 Flare. Three discrete DAS28 Flare subgroups were identified. One was characterised by increases in tender/swollen joint counts (14.4%), a second by increases in symptoms (13.1%), and a third displayed lower flare severity (72.5%). Two discrete Pain Flare subgroups were identified. One occurred following low disease activity and symptoms (88.6%), and the other occurred on the background of ongoing active disease and pain (11.4%). Despite the observed differences between DAS28 and Pain Flares, each was associated with increased disability which persisted beyond the flare episode. Conclusion: Flares are both common and heterogeneous in people with RA. Furthermore our findings indicate that for some patients there is a discordance between inflammation and pain in flare events. This discrete flare subgroups might reflect different underlying inflammation and pain mechanisms. Treatments addressing different mechanisms might be required to reduce persistent disability after DAS28 and Pain Flares.Peer reviewedFinal Published versio