A Comprehensive Analysis of Minority Interest Discounts in Estate and Gift Taxation

2006 ◽  
Vol 4 (1) ◽  
pp. 117-134
Author(s):  
Gregg S. Woodruff ◽  
Craig J. Langstraat ◽  
John M. Malloy
Keyword(s):  
Comprehensive Analysis ◽  
Internal Revenue Service ◽  
Tax Base ◽  
Internal Revenue ◽  
Legal Duty ◽  
History Of ◽  
Minority Interests ◽  
Gift Tax ◽  
Minority Interest Discount

One of the most litigated and adjusted areas in taxation has been the determination of the minority interest discount in estate and gift taxation. Valuation disputes arise because the valuation processes for estate and gift taxation are “inherently imprecise,” and the goals of the taxpayer and Internal Revenue Service (IRS) are diametrically opposed. The IRS's vigorous defense of the estate and gift tax base and the taxpayersa' attempts to pay no more tax than is their legal duty have resulted in a history of situations where the taxpayer and the IRS turn to the courts for adjudication. This paper addresses the basis for a minority interest discount, the determination whether ownership interests are in fact minority interests, and the importance of facts and law in the determination of the minority interest discount. A comprehensive analysis of estate and gift tax cases that determined minority interest discounts is used as a basis for planning ideas to maximize these discounts.

scholarly journals Pharmacometabonomics – the novel way to personalized drug therapy

2017 ◽  
Vol 63 (2) ◽  
pp. 115-123 ◽  
Author(s):  
D.L. Maslov ◽  
E.E. Balashova ◽  
P.G. Lokhov ◽  
A.I. Archakov
Keyword(s):  
Drug Therapy ◽  
System Approach ◽  
Biological Fluids ◽  
Comprehensive Analysis ◽  
Plasma Metabolites ◽  
Therapeutic Drug ◽  
The Novel ◽  
History Of ◽  
Direct Mass Spectrometry

The review is devoted to pharmacometabonomics - a new branch of science focused on personalization of drug therapy through the comprehensive analysis of metabolites of patient's biological fluids. It considers the history of pharmacometabonomic, positioning to other “-omic” sciences, and system approach, realized by this science, in determination of individual therapeutic dose of the drugs and also a technical implementation of pharmacometabonomic based on direct mass spectrometry of blood plasma metabolites. Special attention is paid to a comparative analysis of pharmacometabonomics and other main approaches to personalized therapy in the clinic, such as pharmacogenetics and therapeutic drug monitoring. Finally, prospects of pharmacometabonomics applications in clinical practice were also discussed.

Determination of Fill of Beer Containers

1971 ◽  
Vol 54 (5) ◽  
pp. 1218-1224
Author(s):  
Robert L Schoeneman ◽  
Randolph H Dyer ◽  
Elaine M Earl ◽  
Michael S Greenfield
Keyword(s):  
Carbon Dioxide ◽  
Gravimetric Method ◽  
Internal Revenue Service ◽  
Weights And Measures ◽  
Internal Revenue ◽  
Volumetric Determination

Abstract Since the tax on beer is based on volume, the Internal Revenue Service suggests that beer containers be filled as nearly as possible to the quantity shown on the label, with substantially as much underfill as overfill in each lot. However, the philosophy of weights and measures officials in protecting the consumer is that the beer container should always contain at least as much as the quantity shown on the label, with very little tolerance for underfills. These different attitudes illustrate the need for establishing reasonable and equitable fill tolerances. This paper compares and evaluates 2 methods (volumetric and gravimetric) for the determination of the fill of beer containers. These 2 methods were shown to give comparable results. Samples from 4 large and 4 small breweries were examined. The densities of the different samples and the contents in fluid ounces are tabulated. The effect of beer retention inside the container in the volumetric determination and the variations in container tare weights in the gravimetric method are examined. The effects of carbon dioxide on both methods are also discussed.

scholarly journals Cryptocurrencies for the Payment of Products or Services: Risks, Accounting Practices and Regulations

2019 ◽  
Vol 8 (4) ◽  
pp. 19
Author(s):  
David Allen ◽  
James Aselta ◽  
Russell Engel
Keyword(s):  
Accounting Standards ◽  
Securities And Exchange Commission ◽  
Financial Accounting ◽  
Internal Revenue Service ◽  
Financial Accounting Standards Board ◽  
Internal Revenue ◽  
Blockchain Technology ◽  
History Of ◽  
Regulatory Bodies ◽  
The Subject

This paper examines the risks, accounting practices and disclosures of companies who accept cryptocurrency for the payment of products or services. We provide a brief history of cryptocurrency and blockchain technology that allows the reader to deepen their understanding of the subject before moving on to a discussion of how regulatory bodies such as the Financial Accounting Standards Board (FASB), the Securities and Exchange Commission (SEC) and the Internal Revenue Service (IRS) are treating the accounting for cryptocurrency transactions. 

State-by-State Use of AMA Guides

2019 ◽  
Vol 24 (5) ◽  
pp. 3-7, 16
Keyword(s):  
Expert Testimony ◽  
Narrow Range ◽  
The United States ◽  
Workers Compensation ◽  
Federal Employees ◽  
Permanent Disability ◽  
Sixth Edition ◽  
History Of ◽  
Canadian Provinces

Abstract This article presents a history of the origins and development of the AMA Guides to the Evaluation of Permanent Impairment (AMA Guides), from the publication of an article titled “A Guide to the Evaluation of Permanent Impairment of the Extremities and Back” (1958) until a compendium of thirteen guides was published in book form in 1971. The most recent, sixth edition, appeared in 2008. Over time, the AMA Guides has been widely used by US states for workers’ compensation and also by the Federal Employees Compensation Act, the Longshore and Harbor Workers’ Compensation Act, as well as by Canadian provinces and other jurisdictions around the world. In the United States, almost twenty states have developed some form of their own impairment rating system, but some have a narrow range and scope and advise evaluators to consult the AMA Guides for a final determination of permanent disability. An evaluator's impairment evaluation report should clearly document the rater's review of prior medical and treatment records, clinical evaluation, analysis of the findings, and a discussion of how the final impairment rating was calculated. The resulting report is the rating physician's expert testimony to help adjudicate the claim. A table shows the edition of the AMA Guides used in each state and the enabling statute/code, with comments.

Integrative Approach in Law Understanding: the History of the Origin of Ideas and the Current State

2020 ◽  
Vol 2 (1) ◽  
pp. 115-130
Author(s):  
R. R. Palekha ◽  
Keyword(s):  
Central Place ◽  
Scientific Basis ◽  
Integrative Approach ◽  
Current State ◽  
History Of ◽  
Legal Thinking ◽  
Reliable Knowledge ◽  
The Right ◽  
Fat Formulation

Introduction. Right understanding is the most live, interesting and, at the same time, the uncertain and changeable area of researches which takes the central place as in the general theory of the right, and gains the increasing value in industry jurisprudence that is connected with its considerable teoretiko-methodological and applied potential which is shown in spheres of lawmaking and law-enforcement activity. Thus, right understanding represents research tools of the subject of knowledge which allow to study all range legal and, the based on them, state phenomena for the purpose of obtaining reliable knowledge of state and legal reality. In this regard integrative approach in right understanding which has rich history of the formation and development is of special interest, allows to perceive the right as integrally complete phenomenon, as much as possible retrieves its regulatory abilities and, provides achievement of criteria of scientific research: comprehensiveness, objectivity, historicism. Materials and Methods. In article an attempt of the analysis of integrative approach in right understanding from a position of history of origin of his ideas and assessment of the current state is made. A result of studying of scientific literature, generalization and comparison of the different points of view fat formulation of author’s determination of category “right understanding” and submission of the evidence-based integrative theory of right understanding which as much as possible conforms to requirements of time and has essential regulatory and guarding potential. Results. In article the category right understanding is comprehensively considered, different integrative theories of right understanding from a position of their origin and development are submitted, the value of modern integrative approach in right understanding is shown, perspectives of its further development are evaluated. Discussion and Conclusion. The author comes to the conclusion about the theoretical and methodological consistency and inevitability of the integrative approach in law understanding, which acts as a scientifically grounded type of legal thinking capable of comprehending the law on a truly scientific basis.

Tax Practitioner Credentials and the Incidence of IRS Audit Adjustments

2003 ◽  
Vol 17 (1) ◽  
pp. 1-14 ◽  
Author(s):  
Peggy A. Hite ◽  
John Hasseldine
Keyword(s):  
Random Selection ◽  
Internal Revenue Service ◽  
Internal Revenue ◽  
Tax Returns ◽  
Selection Of

This study analyzes a random selection of Internal Revenue Service (IRS) office audits from October 1997 to July 1998, the type of audit that concerns most taxpayers. Taxpayers engage paid preparers in order to avoid this type of audit and to avoid any resulting tax adjustments. The study examines whether there are more audit adjustments and penalty assessments on tax returns with paid-preparer assistance than on tax returns without paid-preparer assistance. By comparing the frequency of adjustments on IRS office audits, the study finds that there are significantly fewer tax adjustments on paid-preparer returns than on self-prepared returns. Moreover, CPA-prepared returns resulted in fewer audit adjustments than non CPA-prepared returns.

scholarly journals In Situ exploration of the giant planets

2021 ◽  
Author(s):  
O. Mousis ◽  
D. H. Atkinson ◽  
R. Ambrosi ◽  
S. Atreya ◽  
D. Banfield ◽  
...  
Keyword(s):  
Solar System ◽  
Giant Planets ◽  
Atmospheric Composition ◽  
Formation History ◽  
History Of ◽  
Composition Structure ◽  
Galileo Probe ◽  
Probe Measurements

AbstractRemote sensing observations suffer significant limitations when used to study the bulk atmospheric composition of the giant planets of our Solar System. This impacts our knowledge of the formation of these planets and the physics of their atmospheres. A remarkable example of the superiority of in situ probe measurements was illustrated by the exploration of Jupiter, where key measurements such as the determination of the noble gases’ abundances and the precise measurement of the helium mixing ratio were only made available through in situ measurements by the Galileo probe. Here we describe the main scientific goals to be addressed by the future in situ exploration of Saturn, Uranus, and Neptune, placing the Galileo probe exploration of Jupiter in a broader context. An atmospheric entry probe targeting the 10-bar level would yield insight into two broad themes: i) the formation history of the giant planets and that of the Solar System, and ii) the processes at play in planetary atmospheres. The probe would descend under parachute to measure composition, structure, and dynamics, with data returned to Earth using a Carrier Relay Spacecraft as a relay station. An atmospheric probe could represent a significant ESA contribution to a future NASA New Frontiers or flagship mission to be launched toward Saturn, Uranus, and/or Neptune.

scholarly journals Anaphylactic Death: A New Forensic Workflow for Diagnosis

Healthcare ◽  
2021 ◽  
Vol 9 (2) ◽  
pp. 117
Author(s):  
Massimiliano Esposito ◽  
Angelo Montana ◽  
Aldo Liberto ◽  
Veronica Filetti ◽  
Nunzio Di Nunno ◽  
...  
Keyword(s):  
Clinical History ◽  
Rapid Onset ◽  
Mean Value ◽  
Laryngeal Edema ◽  
Tryptase Level ◽  
Antibody Staining ◽  
Life Threatening ◽  
History Of ◽  
Immunohistochemical Techniques

Anaphylaxis is a life-threatening or fatal clinical emergency characterized by rapid onset, and death may be sudden. The margin of certainty about the diagnosis of anaphylactic death is not well established. The application of immunohistochemical techniques combined with the evaluation of blood tryptase concentrations opened up a new field of investigation into anaphylactic death. The present study investigated eleven autopsy cases of anaphylactic death, carried out between 2005 and 2017, by the Departments of Forensic Pathology of the Universities of Foggia and Catania (Italy). An analysis of the medical records was carried out in all autopsies. Seven autopsies were carried out on males and four on females. Of the eleven cases, one showed a history of asthma, one of food ingestion, two of oral administration of medications, six did not refer any allergy history, and one subject was unknown. All cases (100%) showed pulmonary congestion and edema; 7/11 (64%) of the cases had pharyngeal/laryngeal edema and mucus plugging in the airway; only one case (9%) had a skin reaction that was found during external examination. Serum tryptase concentration was measured in ten cases, and the mean value was 133.5 µg/L ± 177.9. The immunohistochemical examination using an anti-tryptase antibody on samples from the lungs, pharynx/larynx, and skin site of medication injection showed that all cases (100%) were strongly immunopositive for anti-tryptase antibody staining on lung samples; three cases (30%) were strongly immunopositive for anti-tryptase antibody staining on pharyngeal/laryngeal samples; and eight cases (80%) were strongly immunopositive for anti-tryptase antibody staining on skin samples. We conclude that a typical clinical history, blood tryptase level >40 µg/L, and strongly positive anti-tryptase antibody staining in the immunohistochemical investigation may represent reliable parameters in the determination of anaphylactic death with the accuracy needed for forensic purposes.

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