155,211 research outputs found
Using Shareholder Notes to Eliminate Section 357(c) Gain: Lessinger v. Commissioner, 872 F.2d 519 (2d Cir. 1989), Correct Result, Wrong Reason
No full textDespite the rather specific statutory framework of Subchapter C of the Internal Revenue Code, which addresses the tax consequences of corporate formation, the courts have repeatedly been called upon to provide a gloss to the statutes to address situations not contemplated by Congress.\u27 In Lessinger v. Commissioner, the Second Circuit encountered a factual situation that compelled the court to again gloss over the plain meaning of the words in the applicable Internal Revenue Code sections to reach the appropriate result. This Article examines the action taken by the Second Circuit in Lessinger and addresses the propriety of the judicial manipulation of statutory language. Further, it examines whether the court arrived at the correct result by using an incorrect approach. Lastly, the author proposes an alternative to the currently accepted interpretation of the statutory language that would make the Second Circuit\u27s approach in Lessinger unnecessary and would not necessitate further legislative action to bring the factual pattern presented by Lessinger within the ambit of the existing statutory objective
Using Shareholder Notes to Eliminate Section 357(c) Gain: Lessinger v. Commissioner, 872 F.2d 519 (2d Cir. 1989), Correct Result, Wrong Reason
No full textDespite the rather specific statutory framework of Subchapter C of the Internal Revenue Code, which addresses the tax consequences of corporate formation, the courts have repeatedly been called upon to provide a gloss to the statutes to address situations not contemplated by Congress.\u27 In Lessinger v. Commissioner, the Second Circuit encountered a factual situation that compelled the court to again gloss over the plain meaning of the words in the applicable Internal Revenue Code sections to reach the appropriate result. This Article examines the action taken by the Second Circuit in Lessinger and addresses the propriety of the judicial manipulation of statutory language. Further, it examines whether the court arrived at the correct result by using an incorrect approach. Lastly, the author proposes an alternative to the currently accepted interpretation of the statutory language that would make the Second Circuit\u27s approach in Lessinger unnecessary and would not necessitate further legislative action to bring the factual pattern presented by Lessinger within the ambit of the existing statutory objective
AMiGA: the arthropodan mitochondrial genomes accessible database
No full textFeijão P, Neiva LS, Azeredo-Espin AML d., Lessinger AC. AMiGA: the arthropodan mitochondrial genomes accessible database. Bioinformatics. 2006;22(7):902-903
O. A. C. Review Volume XLVI Issue 5, February 1934
No full textThe focus of this issue is the preparation for College Royal and recognizing its tenth anniversary. This month's agricultural article is a report from the Dominion Parasite Laboratory on the biological control of pests. Other articles provide an account of the activities of a stage manager and the development of the field of home economics at Macdonald College in Quebec. Campus news addresses the success of the 1934 Conversazione, the commemorating of the sixtieth anniversary of the founding of O. A. C., the attendance at the Canadian Author Lecture, and the successful productions of "The Apple Cart" and "Iolanthe". The Macdonald Institute column comments on the Conversat and women's athletics activities in basketball and the rifle club. The Alumni Record supplies alumni updates.EditorialTen Years of the RoyalRamblings on the RoyalBlame it on the stage managerBiological control of insect pests in CanadaNot for girls onlyCollege lifeLiterary sectionO. A. C. sportsfolioAlumni recordMacdonald newsLetters to the editoradvertisin
O. A. C. Review Volume XXXVI Issue 12, August 1924
No full textThis slim summer issue contains the address given by the agricultural section of the British Association for the Advancement of Science, and a report on the visit of this association to the O. A. C. Other articles include instructions on increasing strawberry production and a biography of the author John Masefield. The editorial comments on Rhodes Scholars. The Alumni column provides an update of alumni activities. This issue does not contain a Macdonald column.JoyPresent-day problems in crop productionAfter the strawberry harvestJohn MasefieldVisit of the Agricultural Section of the British Association for the Advancement of ScienceEditorialCollege lifeAlumniadvertisin
Going Beyond Counting First Authors in Author Co-citation Analysis
No full textThe 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
Measurement of the ratio of prompt χ c to J / ψ production in pp collisions at √s = 7 TeV
No full textThe prompt production of charmonium χ c and J / ψ states is studied in proton-proton collisions at a centre-of-mass energy of √s = 7 TeV at the Large Hadron Collider. The χ c and J / ψ mesons are identified through their decays χ c → J / ψ γ and J / ψ → μ + μ - using 36 pb - 1 of data collected by the LHCb detector in 2010. The ratio of the prompt production cross-sections for χ c and J / ψ, σ (χ c → J / ψ γ) / σ (J / ψ), is determined as a function of the J / ψ transverse momentum in the range 2 < p T J / ψ < 15 GeV / c. The results are in excellent agreement with next-to-leading order non-relativistic expectations and show a significant discrepancy compared with the colour singlet model prediction at leading order, especially in the low p T J / ψ region
The Thursday Murder Club: Launching a megabrand author - a publishing case study
No full textIn 2020, the Christmas book charts in the UK made headlines: Barack Obama’s eagerly awaited autobiography, The Promised Land, was beaten to the top spot by The Thursday Murder Club by Richard Osman, a debut cosy crime novel set in a retirement village. Not only did Osman’s book beat the former US president’s expected bestseller, it also broke records, becoming the fastest-selling debut crime novel of all time. Although Osman has a certain level of fame in the UK from his TV appearances on shows such as Pointless, his celebrity status does not entirely explain the novel’s huge sales. This article tracks the acquisition, publication, and promotion journey of The Thursday Murder Club in order to understand the industry and cultural context of its success and to interrogate the role of celebrity in the creation of author brands. The findings suggest that the unexpected scale of the success of the book owed to a number of factors, including in-depth editing by the novel’s agent, editor, and author to tighten up the plot, an extensive and strategic promotional campaign, the pandemic (which drove interest in the book’s genre and themes), and the quality of the writing. We find that the book’s success was accentuated by Osman’s celebrity status rather than being entirely reliant on it. This research adds to the growing scholarship on celebrity authorship by means of an in-depth case study and provides insight into the processes behind publishing a ‘celebrity’ book and launching a megabrand author
A Theme Analysis of Experiences Reported by Adult Children of Alcoholics in Online Support Forums
No full textGrowing up with an alcoholic parent can have a lasting effect on children and contribute to a variety of challenging outcomes in adulthood. This study identified the various experiences that adult children of alcoholics discuss with their peers in online support groups. Trained coders conducted a thematic analysis of 504 message board posts collected over a period of 60 days from three different online support groups to identify issues that children of alcoholics face in adulthood. Seven themes emerged from the analysis: a) empowerment through support, b) interference of parent in adulthood, c) connection to inner child and need to re-parent, d) low self-esteem and insecurity, e) anger and resentment, f) romantic relationship problems, and g) problems communicating. The results of this study provide insight into the issues that adult children of alcoholics need to address as part of their own recovery and suggest avenues of exploration for practitioners who work with high risk families.Peer reviewe
TaxMan: a taxonomic database manager
No full textAbstract Background Phylogenetic analysis of large, multiple-gene datasets, assembled from public sequence databases, is rapidly becoming a popular way to approach difficult phylogenetic problems. Supermatrices (concatenated multiple sequence alignments of multiple genes) can yield more phylogenetic signal than individual genes. However, manually assembling such datasets for a large taxonomic group is time-consuming and error-prone. Additionally, sequence curation, alignment and assessment of the results of phylogenetic analysis are made particularly difficult by the potential for a given gene in a given species to be unrepresented, or to be represented by multiple or partial sequences. We have developed a software package, TaxMan, that largely automates the processes of sequence acquisition, consensus building, alignment and taxon selection to facilitate this type of phylogenetic study. Results TaxMan uses freely available tools to allow rapid assembly, storage and analysis of large, aligned DNA and protein sequence datasets for user-defined sets of species and genes. The user provides GenBank format files and a list of gene names and synonyms for the loci to analyse. Sequences are extracted from the GenBank files on the basis of annotation and sequence similarity. Consensus sequences are built automatically. Alignment is carried out (where possible, at the protein level) and aligned sequences are stored in a database. TaxMan can automatically determine the best subset of taxa to examine phylogeny at a given taxonomic level. By using the stored aligned sequences, large concatenated multiple sequence alignments can be generated rapidly for a subset and output in analysis-ready file formats. Trees resulting from phylogenetic analysis can be stored and compared with a reference taxonomy. Conclusion TaxMan allows rapid automated assembly of a multigene datasets of aligned sequences for large taxonomic groups. By extracting sequences on the basis of both annotation and BLAST similarity, it ensures that all available sequence data can be brought to bear on a phylogenetic problem, but remains fast enough to cope with many thousands of records. By automatically assisting in the selection of the best subset of taxa to address a particular phylogenetic problem, TaxMan greatly speeds up the process of generating multiple sequence alignments for phylogenetic analysis. Our results indicate that an automated phylogenetic workbench can be a useful tool when correctly guided by user knowledge.</p
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