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Private foundations ::excess business holdings (section 4943) /
No full text"Tax Management Portfolio, Private Foundations--Excess Business Holdings (Section 4943), No. 473-2nd, explains the application and operation of [section] 4943 of the Internal Revenue Code, which imposes an excise tax on the excess business holdings of private foundations and certain donor advised funds and supporting organizations. As a general rule, under [section] 4943, the combined holdings of a private foundation and its disqualified persons are limited to 20% of the voting stock in a business enterprise that is a corporation or 20% of the profits or beneficial interest in a business enterprise that is a partnership, limited liability company, joint venture or unincorporated association.
Better Late Than Never: Incorporating LLCs Into Section 4943
Get PDFPart I of this Article traces the historical development of Code Section 4943 and the business entanglement issues that the Code Section was designed to combat. It then discusses developments in the law that occurred after the passage of Section 4943 that have implications for its structure, most importantly the introduction of the LLC. Part II describes the current statutory scheme of Section 4943, and the ambiguity in the manner in which it applies, and the practical problems and abuses that potentially arise from this ambiguity. In Part III, the Article reviews various options for clarifying the treatment of Section 4943 and evaluates them in light of the ongoing debate regarding the intersection of charity and business. This Article concludes, in Part IV, with a recommendation for change that provides administrative clarity and minimizes the possibility of abuse while allowing for modern investment practices
Block Card 4943 Elmhurst Road
No full textThis image was produced by the Auditor's Office in Lucas County, Ohio for tax assessment purposes. Associated dates are approximate. Descriptive terms related to this photograph include: Ranch Style | Dwelling | 4943 Elmhurst Road (Toledo, Ohio) | Elmhurst Park Addition (Toledo, Ohio) | Deveaux Area (Toledo, Ohio) | West Toledo (Toledo, Ohio
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Gas Tungsten Arc Welding of Aluminum Alloys with Nanocomposite 4943 Filler Material
Get PDFAluminum alloy 4943, specifically developed for arc welding, offers higher tensile and yield strength than AA 4043 and AA 4643 while maintaining weldability characteristics such as fluidity, shrinkage, solidification range, and low weld cracking sensitivity[1]. Thus, it has become a preferred filler material option for high quality, repeatable welds, especially for 6xxx series aluminum. However, the strength and applicability of aluminum alloy welded joints with AA 4943 filler material remains limited despite excellent weldability. Previous studies[2] have shown the promise of introducing ceramic nanoparticles into the aluminum alloy filler material to enhance mechanical properties and avoid problems typically associated with aluminum welding, such as solidification cracking. This idea has been extrapolated to AA 4943, which can be modified to produce welds with nanocomposite filler material. Any perceived benefits would have implications for many industries, in particular bicycle manufacturing which commonly uses AA 6061 for frames.By introducing TiB2 nanoparticles into AA 4943 to produce welds of popular aluminum alloys through gas tungsten arc welding (GTAW), the effects of this nanocomposite filler were studied through characterization methods including microhardness testing, microstructure determination, and tensile testing. Little to no enhancements to mechanical properties were observed for welds with AA 4943 TiB2 nanocomposite filler when compared to welds with AA 4943 reference filler. Large clusters of TiB2 nanoparticles were observed in the secondary phase of the nanocomposite AA 4943 following casting and also observed in the as-welded samples in the weld zone. These clusters may be hindering ductility and providing a brittle fracture surface, lowering ultimate tensile strength of the samples and offering no grain size refinements. Additional manufacturing methods for the nanocomposite filler, such as extrusion, may offer a solution to the TiB2 clustering effect and superior nanoparticle distribution
Linked collectors and determiners for: Coleção Zoológica da Universidade Federal de Mato Grosso do Sul - Hymenoptera (ZUFMS-HYM).
No full textNatural history specimen data linked to collectors and determiners held within, "Coleção Zoológica da Universidade Federal de Mato Grosso do Sul - Hymenoptera (ZUFMS-HYM)". Claims or attributions were made on Bionomia by volunteer Scribes, <a href="http://bionomia.net/dataset/65021239-bcce-4943-b440-f4195d5d6d70">https://bionomia.net/dataset/65021239-bcce-4943-b440-f4195d5d6d70</a> using specimen data from the dataset aggregated by the Global Biodiversity Information Facility, <a href="https://gbif.org/dataset/65021239-bcce-4943-b440-f4195d5d6d70">https://gbif.org/dataset/65021239-bcce-4943-b440-f4195d5d6d70</a>. Formatted as a Frictionless Data package
Abstract 4943: Circulating immunologic markers and risk of multiple myeloma and its precursor disease: A nested case-control study
No full textAbstract Objective: Severe immune dysregulation is a strong risk factor for multiple myeloma (MM), and experimental studies have implicated chemokines and pro-angiogenic cytokines in MM pathogenesis. We investigated whether circulating immune markers were prospectively associated with MM and its precursor, monoclonal gammopathy of undetermined significance (MGUS), in the Prostate, Lung, Colorectal and Ovarian Cancer Screening Trial. Methods: We characterized levels of 43 immune markers in banked sera from 243 MM cases, 506 subjects with MGUS (including those with light-chain disease) who did not progress to MM, and 258 MGUS-free controls using Luminex-based multiplex assay panels. Odds ratios (ORs) and 95% confidence intervals (CIs) for MM and MGUS were estimated using multivariate-adjusted polytomous logistic regression models. Results: Relative to MGUS-free controls, we observed statistically significant associations with MM risk for six markers using a false discovery rate of 10%, including several chemokines (MCP-2/CCL8, fourth quartile vs first: OR 2.1; 95% CI 1.2-3.7; Ptrend=0.017 and SDF-1/CXCL12, 2.6; 1.5-4.4; Ptrend=2.9x10-4), angiogenesis markers (ANG-2, 3.0; 1.7-5.3; Ptrend=1.3x10-4 and HGF, 3.0; 1.7-5.1; Ptrend=2.8x10-5), and growth factors (EGF, 3.2; 1.9-5.5; Ptrend=1.9x10-6 and BMP-9, 2.3; 1.4-4.0; Ptrend=3.3x10-4). Associations with these markers remained after restricting to MM cases diagnosed ≥8 years after blood collection although risk estimates were somewhat attenuated (Ptrend≤0.07). MCP-2/CCL8, SDF-1/CXCL12, and HGF were also significantly elevated among those with MGUS compared with MGUS-free controls (Ptrend≤0.04). Four markers were associated with progression from MGUS to MM after adjusting for clinical characteristics such as M-protein concentration, serum free light-chain ratio, and immunoglobulin type (ANG-2, fourth quartile vs first: OR 2.5, 95% CI 1.4-4.6; HGF, 2.6, 1.4-5.0; EGF, 3.3, 1.8-6.0; and BMP-9, 1.9, 1.0-3.4); dose-response trends were statistically significant for all four markers (Ptrend≤0.03). Conclusions: This is, to our knowledge, the first prospective study to investigate circulating immunologic markers in relation to MM risk and progression from MGUS to MM. Our findings provide insights into potential biological mechanisms associated with MM development and may have clinical utility for improving risk stratification models assessing the likelihood of progression from MGUS to clinically manifest MM. Citation Format: Jonathan N. Hofmann, Ola Landgren, Hormuzd Katki, Troy Kemp, Loredana Santo, Charlene McShane, Qing Lan, Nathaniel Rothman, Ligia Pinto, Ruth Pfeiffer, Allan Hildesheim, Mark Purdue. Circulating immunologic markers and risk of multiple myeloma and its precursor disease: A nested case-control study [abstract]. In: Proceedings of the American Association for Cancer Research Annual Meeting 2018; 2018 Apr 14-18; Chicago, IL. Philadelphia (PA): AACR; Cancer Res 2018;78(13 Suppl):Abstract nr 4943
Linked collectors and determiners for: Coleção Zoológica da Universidade Federal de Mato Grosso do Sul - Hymenoptera (ZUFMS-HYM).
No full textNatural history specimen data linked to collectors and determiners held within, "Coleção Zoológica da Universidade Federal de Mato Grosso do Sul - Hymenoptera (ZUFMS-HYM)". Claims or attributions were made on Bionomia by volunteer Scribes, <a href="http://bionomia.net/dataset/65021239-bcce-4943-b440-f4195d5d6d70">https://bionomia.net/dataset/65021239-bcce-4943-b440-f4195d5d6d70</a> using specimen data from the dataset aggregated by the Global Biodiversity Information Facility, <a href="https://gbif.org/dataset/65021239-bcce-4943-b440-f4195d5d6d70">https://gbif.org/dataset/65021239-bcce-4943-b440-f4195d5d6d70</a>. Formatted as a Frictionless Data package
Going Beyond Counting First Authors in Author Co-citation Analysis
Get PDFThe present study examines one of the fundamental aspects of author co-citation analysis (ACA) - the way co-citation
counts are defined. Co-citation counting provides the data on which all subsequent statistical analyses and mappings
are based, and we compare ACA results based on two different types of co-citation counting - the traditional type that
only counts the first one among a cited work's authors on the one hand and a non-traditional type that takes into
account the first 5 authors of a cited work on the other hand. Results indicate that the picture produced through this non-traditional author co-citation counting contains more coherent author groups and is therefore considerably clearer. However, this picture represents fewer specialties in the research field being studied than that produced through the traditional first-author co-citation counting when the same number of top-ranked authors is selected and analyzed. Reasons for these effects are discussed
Variations on the Author
Get PDF“Variations on the Author” discusses two of Eduardo Coutinho’s recent films (Um Dia na Vida, from 2010, and Últimas Conversas, posthumously released in 2015) and their contribution to the general question of documentary authorship. The director’s filmography is characterized by a consistent yet self-effacing form of authorial self-inscription: Coutinho often features as an interviewer that rather than express opinions propels discourses; an interviewer that is good at listening. This mode of self-inscription characterizes him as an author who is not expressive but who is nonetheless markedly present on the screen. In Um Dia na Vida, however, Coutinho is completely absent form the image, while Últimas Conversas, on the contrary, includes a confessional prologue that moves the director from the margins to the center of his films. This article examines the ways in which these works stand out in the filmography of a director who offers new insights into the notion of cinematic authorship
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