1,722,462 research outputs found
The Enforcement of IRS Summonses and Section 7609
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This Note argues that because the Tenth Circuit decision ignores important policy concerns dealing with the efficiency of the IRS, failing to comply with notice requirements under Section 7609(a) should be analyzed under the totality of the circumstances standard. Part I discusses the history and development of Section 7609(a) and notice requirements for third-party summonses in IRS investigations. Part II outlines the general requirements for the enforcement of an IRS summons and how Section 7609(a) is analyzed in light of those requirements. Part III discusses the current circuit split and the significance of each respective court’s holdings and reasoning. Part IV argues that the Tenth Circuit’s approach, while providing more leverage for taxpayers, ignores important policy arguments. It also argues that the Second, Eleventh, and Sixth Circuits’ totality of the circumstances approach to Section 7609(a) violations is more appropriate. Finally, it discusses a number of factors that may improve that approach
Benthic fluxes of dissolved organic nitrogen in the Lower St. Lawrence Estuary and implications for selective organic matter degradation
Get PDFThe distribution of dissolved organic nitrogen (DON) and carbon (DOC) in sediment porewaters was determined at nine locations along the St. Lawrence estuary and in the gulf of St. Lawrence. In a previous manuscript (Alkhatib et al., 2012a), we have shown that this study area is characterized by gradients in the sedimentary particulate organic matter (POM) reactivity, bottom water oxygen concentrations, and benthic respiration rates. Based on the porewater profiles, we estimated the benthic diffusive fluxes of DON and DOC in the same area. Our results show that DON fluxed out of the sediments at significant rates (110 to 430 μmol m−2 d−1). DON fluxes were positively correlated with sedimentary POM reactivity and varied inversely with sediment oxygen exposure time (OET), suggesting direct links between POM quality, aerobic remineralization and the release of DON to the water column. DON fluxes were on the order of 30 to 64% of the total benthic inorganic fixed N loss due to denitrification, and often exceeded the diffusive nitrate fluxes into the sediments. Hence they represented a large fraction of the total benthic N exchange, a result that is particularly important in light of the fact that DON fluxes are usually not accounted for in estuarine and coastal zone nutrient budgets. In contrast to DON, DOC fluxes out of the sediments did not show any significant spatial variation along the Laurentian Channel (LC) between the estuary and the gulf (2100 ± 100 μmol m−2 d−1). The molar C / N ratio of dissolved organic matter (DOM) in porewater and the overlying bottom water varied significantly along the transect, with lowest C / N in the lower estuary (5–6) and highest C / N (> 10) in the gulf. Large differences between the C / N ratios of porewater DOM and POM are mainly attributed to a combination of selective POM hydrolysis and elemental fractionation during subsequent DOM mineralization, but selective adsorption of DOM to mineral phases could not be excluded as a potential C / N fractionating process. The extent of this C- versus N- element partitioning seems to be linked to POM reactivity and redox conditions in the sediment porewaters. Our results thus highlight the variable effects selective organic matter (OM) preservation can have on bulk sedimentary C / N ratios, decoupling the primary source C / N signatures from those in sedimentary paleoenvironmental archives. Our study further underscores that the role of estuarine sediments as efficient sinks of bioavailable nitrogen is strongly influenced by the release of DON during early diagenetic reactions, and that DON fluxes from continental margin sediments represent an important internal source of N to the ocean
California Poll: 7609 -- November 13-24, 1976
No full textThe Field Poll, established in 1945 as The California Poll by Mervin Field, has operated continuously as an independent, non-partisan, media-sponsored public opinion news service. Each year the Field Polls cover a wide range of political and social topics examining California public opinion. Continuing measures are made of voter support for leading political figures vying for major state and federal offices, job ratings of important political figures and reactions to significant political events. Voter awareness, understanding and predispositions of major campaign issues and salient statewide ballot propositions are also tracked over time. For poll 7609 N=1033
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
Appropriate Similarity Measures for Author Cocitation Analysis
Get PDFWe provide a number of new insights into the methodological discussion about author cocitation analysis. We first argue that the use of the Pearson correlation for measuring the similarity between authors’ cocitation profiles is not very satisfactory. We then discuss what kind of similarity measures may be used as an alternative to the Pearson correlation. We consider three similarity measures in particular. One is the well-known cosine. The other two similarity measures have not been used before in the bibliometric literature. Finally, we show by means of an example that our findings have a high practical relevance.information science;Pearson correlation;cosine;similarity measure;author cocitation analysis
Dispelling the Myths Behind First-author Citation Counts
Get PDFWe conducted a full-scale evaluative citation analysis study of scholars in the XML research field to explore just how different from each other author rankings resulting from different citation counting methods actually are, and to demonstrate the capability of emerging data and tools on the Web in supporting more realistic citation counting methods. Our results contest some common arguments for the continued
use of first-author citation counts in the evaluation of scholars, such as high correlations between author rankings by first-author citation counts and other citation
counting methods, and high costs of using more realistic citation counting methods that are not well-supported by the ISI databases. It is argued that increasingly available digital full text research papers make it possible for citation analysis studies to go beyond what the ISI databases have directly supported and to employ more
sophisticated methods
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