ShantanuT01/DACTYL-Pretraining huggingface dataset:
Introduction The tax of the $11,000 fees paid to the attorney by Sarah is a fixed amount hence no deductions will be made on the value. This memo identifies the judgmental considerations and relevant section of the law that explains how the decision was made. Relevant facts In this case Sarah, the petitioner, clearly understands the market value of the property she acquired. The property, a parcel of land, is the property inherited from her mother meaning that the acquisition and ownership of the property are not meant for the sole purpose of sale. Receiving the parcel in 2009 and inquiring about the market value of the property does not rule out the prospects of a future sale. The intentions of increasing the number of residences per acre after defining the reason as to why the price low indicated “future sale”. Consequently, after the Texas County Board of Supervisors began deliberating on the enactment of the zoning law, she suspended the case appeal and after the ruling, the new value of the property was raised at $25,000 from $15,750. She incurred attorney fees of $11,000. The paradox involves the determination of the status of these charges as either deductible or not. Issues identified The cost incurred in this case charges for the services offered by the attorney. She did not incur them in “reproducing” the property. In addition, she is an economist meaning she is aware of the market-value price of land, hence she will do everything possible to get the best value of the property. Should the cost incurred by Sarah as attorney’s fees are deducted? Conclusion The amount of $11,000 is not deductible and is capitalized. This is according to IRS 263A-1T which states that in case there are costs incurred in a new building or for activities aimed at improving the quality or increasing the value of a building, there will be no deduction allowed. The amount is the attorney’s fee and is not for tangible improvements to the land according to IRS 263A (g) 1 which includes the actions of building, constructing, installing, manufacturing, developing, or improving as the only means by which the amount can be deducted. It is therefore concluded that the amount should not be taxed. An example of the regulation governing capital expenditure provided by the department of the treasury is IRS 1.263A-2T. Capital expenditure under this section has been defined as the cost incurred when acquiring or creating interest in land which includes minerals and timber rights among others. This supports that the fee paid by Sarah to the attorney should be capitalized. Authorities and reasoning This case is supported by the ruling of Lee D. and Marjorie L. Hustead v. Commissioner, U.S. Tax Court, CCH. 50,022(M), T.C. Memo. 50,022(M), 68 T.C.M. 342, T.C. Memo, 1994-374, (199
Executive Summary This paper is an innovation report for Tata Motors. It is divided into six sections. The first one is the introduction part, which provides a background to the study and sets the stage for the rest of the paper. The second segment is the innovation theory review, which explores key theoretical underpinnings of the study by examining the role of the diffusion of innovations theory and the five-stage high involvement framework in Tata’s innovation systems. An analysis of the internal factors of the firm that influence its innovation processes are explained in the third section of the paper. It includes an examination of the company’s leadership processes (participative), organisation structure (flat), and culture (collectivism). A comparative review of the firm’s external strategy demonstrates that it pursues an innovation strategy through the TGIF platform and subscribes to a customization philosophy to manage market forces. Collectively, these analyses pave the way for the recommendations section, which suggests that Tata’s innovation processes should focus on the science of delivery and not on the art of discovery. The last section of the report summarises these findings in the conclusion part. Introduction Tata Corporation was started in the mid-1940s and has since grown to be on
Transformation and modernization in Boston from 1950 to 1970 Boston is one of the cities of the world with fascinating history. Its foundation was laid in 1630 followed by a series of events, which led to developing the city into what it is today. Bostonians were determined to develop the city by erecting structures around a port. As the area grew, more needs emerged, evoking the need for industries for the manufacture of consumables and other products. This essay analyses the transformation and modernization in Boston from 1950 to 1970. By the year 1950, the city began experiencing a wide range of transformations. There were countable major buildings that were erected in the city. Importantly, most of manufacturing industries found it hard to operate in the city because of high cost of production. As a result, a number of them closed their operations and shifted to the southern side of the city, where labor was believed to be affordable. During this time, Boston had several assets including but not limited to hospitals, banks and learning institutions (O’Conner 37). Politicians moved in to prevent cont
For several weeks, between December 2010 and March 2011, the world was treated to a show of uprisings in Tunisia and Egypt. Unlike the common military coup de tars, citizens of Tunisia and Egypt successfully depose long-ruling dictators through civil demonstrations. It all started in Tunisia in December 2010 when citizens joined a nationwide mass action protesting against President Zine El Abidine Ben Ali’s oppressive rule. A few weeks later, Egyptians joined the dance protesting against President Hosni Mubarak oppressive rule. The results in both countries were the same; citizens through mass action managed to oust long ruling dictators. From an outward look, these countries seemed more developed compared to most African countries. Yet, their citizens became so frustrated and desperate, so much so that they decided to fight for their own course. Therefore, the question is, why did these governments fall? The answer remains the same for both; lack of democracy characterized by dictatorship and oppression. We know of successful non-democratic countries like Iran and China, but the former, their rule was too much of authoritarian. Fortunately, citizens managed to bring down governments they believed were the main obstacle to their democracy. Nevertheless, do these events mark the beginning of democracy in Tunisia and Egypt? This essay, therefore, seeks to answer these two important questions. Reasons for the fall of Tunisia and Egypt’s governments Both Egypt and Tunisia’s governments had several similarities. To begin with, they both had the longest serving presidents in their history. Whereas President Ben Al
According to the issue of McFadden’s case, it is obvious that it was reasonable for the detective to stop the two men. The two men had portrayed suspicious behavior by walking several times through the store as if they were targeting something (Rios, 2020). The fourth amendment of law gives police a permit to stop suspects at a reasonable point. Frisking of the suspects was necessary, the detective had to do it to know if they carried any potentially dangerous items with them. The fourth amendment policy also approves the conduction of searches under critical circumstances without a warrant. The act mentioned above also allows for frisking suspicious parties upon reasonable suspicion. It would have not made any difference if the men walked by the store every three times. However, in the case of each of them walking by once, a difference could have been made since no one would suspect them. Since the two men walked many times through the store path while staring through the window this could serve as an indicator of a potentially unlawful act. One of the factors that must have led the detective to believe that his suspicion was reasonable is well illustrated at the point where the detective identified himself as a police officer. He asked the two men their names and they responded offensively, which indicated that they could indeed plan an unlawful act. In addition, when the police officer spotted pistols in the men’s pockets it was a sign of unlawful behavior. According to Rios (2020), the first amendment allows police to deal with those whose speech goes beyond control. There is a difference between “stop and frisking” and “search and seizure”. Stop and frisk to a situation where the police undertake a non-welcoming stop on a suspect after realizing that they care about or planning to commit a crime (Rios, 2020). On the other hand, search and seizure is a process whereby police undertake a search after a crime has occurred (Rios et al., 2020). Searches are normally done after authorization is received from judges and is required to be conducted as soon as possible after an arrest. Reference Rios, V. M., Prieto, G., & Ibarra, J. M. (2020). Mano Suave-Mano Dura: Legitimacy policing and Latino stop- and- frisk. American Sociological Review, 85 (1) 58-75.
Retention is the process of holding back students in their previous grade especially those who have failed to meet the set requirement of the institution they are learning in. The students are normally forced to do the same grade again: that which they had covered the year before (Shepard & Smith 2009). There are however both negative and positive effects of retaining students. Some of the negative effects include: social-emotional problems, school dropout, and poor academic achievements in the long run. Positive effects includes: it gives the students the chance to learn again and gain new skills and knowledge that they had not obtained in the previous academic year. This paper explains whether retention work in schools today taking into consideration both the positive and negative effects of retention process Many at times, schools and teachers advocate for retention of some students because of they think that the child is still young, when a child have limited academic skills, they have poor language skills, they are not mature enough to handle the next grade and if the student miss classes frequently. For a long period of time, retention has been debatable on whether to implement it in schools or not. Extreme research has been conducted on potential alternatives that can be used in place of retention. It has however been found that retention is of no benefit to a child and there are high chances that it will have many negative effects on the child. A study was conducted whereby students who had poor academic skills were combined in the same class with those students who were repeating their grade. After some period of time, they graded them based on their performance and compared them to their previous performances. The results showed that all the students in this class experienced relatively high test scores after retention during their first study year but in year two, three and four, their performance score was poor (Pawlas & Olivia 2007). This clearly shows that there are no benefits obtained in retaining students and it proves that retention does not work. However, researchers still believe that later on retention might prove to be effective. In addition to being expensive, there are no academic benefits or advantages obtained from retention. This is because it does not add any value to the students. The academic performances of those students who had repeat was poor as compared to that of those other students who had been promoted. However, educators still continue with the procedure of retaining weak students even after retention has proved to be ineffective. Today, retention is still a major approach used by teachers with a hope and intention that it will cure their academic problems and failures. The practice of retention has persisted even after literature and research proved that it brings no benefit nor add any value to students when it comes to personal adjustment and achievement instead retention had proved to be of harm to the students. According to a study conducted on the impacts of retention on individual achievements an
Adult Education Act Adult Education Act (AEA) (1991) was proposed and approved by Congress in 1966 and marked the start of projects developed for the improvement of the economic state of disadvantaged populations.   * Economy: the Act was aimed at enhancing the economy by giving citizens a possibility to obtain education and, as a result, get better employment options; the Act developed people’s economic self-sufficiency;   * Demographics: Americans 16 years of age or older;   * Ethics: the Act was developed only for the American citizens; thus, it left out ethnic and racial minorities, and cannot be considered entirely ethical;   * Political climate: the Act enabled political equality of all US citizens (“Adult education act” [AEA], 1991). Adult Education and Family Literacy Act The objectives of Adult Education And Family Literacy Act (AEFLA) (2014) are similar to those covered by AEA. However, AEFLA also includes a rather crucial aim of helping parents and guardians obtain the necessary skills to be able to participate in their children’s educational process.   * Economy: AEFLA helps to develop the country’s economy by providing people an opportunity to enhance their job situation;   * Demographics: Americans and foreign-born adults;   * Ethics: AEFLA gives equal possibilities for all adults living in the USA;   * Political climate: the Act enhances political climate in the country (“Adult education and family literacy act” [AEFLA], 2014). Assessment of Policies in Terms of Interest for Adult Education AEA is highly significant for the organization of adult education as it was among the pioneers of such projects and it was developed to enhance people’s well-being. Also, the policy supports people’s basic values, which makes it an important step on the way to forming a better nation (Fowler, 2013). The significance of AEFLA for adult education is revealed in its focus on the parents’ ability to participate in children’s education. Adults participating in the program have better chances to assimilate in society as citizens and parents (AEFLA, 2014). Thus, this policy corresponds to the requirement of comprehending the unique requirements of adults (Kazis et al., 2007). Both policies have many advantages as well as some disadvantages. AEA and AEFLA help citizens to achieve better success in employment and earn more money to support themselves and their families (Center for applied linguistics, 20
Artificial Intelligence (AI) is an ever-growing technology that allows web users to receive much information and facilitate life using elaborate algorithms. What once was thought to be science fiction about the role of cybernetics now is an inevitable reality. AI-powered innovations have changed multiple vehicles, devices, and other equipment in every sphere of human activity, but most importantly, they influenced the digital world (Abou-Zahra et al., 2018). They impacted the web developers and their users by providing a range of products and services that alleviate net surfing. In particular, artificial intelligence made it possible for impaired people by creating summarization, image, and voice recognition. Even though AI technologies can make the web more accessible to disabled people with the help of assistive technologies, they also have several imperfections. An essential part of network availability is the versatility of the content per the needs and inclinations of individual customers. This can be a significant visual change to the content, such as changing the text style, size, and division, to make the content more fundamentally customized. In particular, progress in characteristic language provides several examples of how human-created consciousness can support such a change in substance. AI can calculate people’s needs and preferences and adapt content to them. Nonetheless, the web should also be suitable to disabled people’s intentions; therefore, AI helps them to access the net with special assistive technologies. Primarily, language recognition technologies based on AI allow website users to translate texts and see captions and subtitles. Many leading companies created platforms for improving captioning and translating because such an approach helps disabled people receive information (Wolf, 2020). Moreover, speech recognition algorithms empower deaf or half-deaf people to use networks adjusting to their needs. Language recognition machines also help emit grammatical, punctuational, and semantical mistakes in the text, allowing users to sound more literate. Some of the innovative organizations also create different interpretations of the language and the subtitles of the disabled’s answers. As part of its goal of creating a more comprehensive organization, Microsoft has made Microsoft Translator, a human-made innovation of mind-based correspondence for deaf and hard hearing people. Although the design still has some flaws including wrong translation and incorrect subtitles insertion. Nevertheless, it creates numerous opportunities for impaired people to perceive the text. Another point concerns automatic image recognition in the worldwide nets, such as Instagram or Facebook. The technology was implemented to help blind or half-blind people understand the content of the images presented. For instance, Google developed an algorithm that lets the disabled recognize images and differentiate objects in them; i
Dyspnea, also described as “shortness of breath”, is a common health complication in patients with chronic obstructive pulmonary disease (COPD). Statistically, between 90 and 95 percent of patients with COPD experience dyspnea (Donesky-Cuenco, Nguyen, Paul & Carrieri-Kohlman, 2009). Many patients are admitted to Intensive Care Units when the symptoms of COPD and dyspnea become severe. Consequently, nurses face a complex task to detect the problem and provide complex therapeutic and non-medical solutions to alleviate the symptoms of dyspnea in COPD patients. The current state of literature provides vast empirical evidence supporting the relevance of various dyspnea management models and interventions. Nurses should rely on evidence-based research, while developing the most effective approach to dyspnea in COPD patients admitted to ICU. Patient Situation A 62-year-old man is admitted to the Intensive Care Unit with the symptoms of breathlessness. A week ago, the patient was presented to the hospital emergency unit with the following complaints: shortness of breath, difficulty speaking, difficulty laughing. However, after a quick medical investigation, he was released from the hospital with the recommendation to use his metered dose inhaler at home. The patient has a very long history of smoking (more than 40 years). His medical history also shows he has COPD. From his history, it is evident that the patient quit smoking 2 years ago. Symptoms The patient looks very pale. Upon being admitted to the intensive care unit, the blood pressure is 130/90, pulse 133, respirations 26. The chest x-ray exam reveals hyperexpanded lung fields. The expiratory phase is prolonged, and wheezes are present in all lung fields. Breath sounds are decreased on both sides. The patient exhibits the decreased level of consciousness bordering on confusion. Poor air excursion, crackles, and chest pain are present. Cough is unproductive. Fever is present. Accessory muscle use suggests of COPD exacerbation. A Review of Literature Drugs in dyspnea management Certainly, pharmacology is one of the fundamental elements of dyspnea management. The use of opioids is, probably, the most debated element of dyspnea management, especially in elderly patients. However, the results of certain randomized trials confirm their efficacy. Mahler et al. (2009) suggest that “endogenous opioids modify dyspnea during treadmill exercise in patients with chronic obstructive pulmonary disease by apparent alteration of central perception” (p.771). Patients and family caregivers also report positive impressions from using opioids for refractory dyspnea, especially in patients with the history of COPD (Rocker, Young, Donahue, Farquhar & Simpson, 2012). Unfortunately, not all nurses are willing to use opioids for dyspnea in COPD patien
Introduction The pregnant women, cancer clinics, and the cardio clinics for the cancer patients are all located. These are majorly people in the middle age group and those in their late sixties and above. The elderly and the critically ill patients are provided with wheelchairs and stretchers to facilitate their movement as deemed appropriate. Being a major hospital in the town, the number of patients housed never goes below eight hundred. In case of calamities such as a bomb blast or fire incident in another location, the number can increase to full capacity. Lastly is the more volatile group of visitors. This group has no particular limit to its number. It includes the patients’ relatives and friends who are there to provide them with emotional and financial support during the entire process of healing. Secondly, there are those visiting the staff and still those coming to make inquiries for future treatments. Every floor has a large waiting area where the visitors wait before being permitted to view their sick relatives and friends. There is a large car park provided to take care of the staff and visitors’ needs both on the front and exterior location of the building (see diagram 3). In addition, the number of occupancy at the hospital at night is usually less than that during the day. The visiting hours end at 10.00 pm at night and the majority of the staff have retired to their homes. Activities and uses Numerous activities are carried out in the hospital simultaneously. From these, fires may result due to negligence and carelessness or be purely accidental. First, we have the nurses handling all the inflammable chemicals in their administration of treatment as designated by the doctors. Oxygen therapy is normally conducted as a medical intervention in chronic and acute patient health complications. Oxygen is required for body metabolism, and the amount naturally available (21% of room air) may not be sufficient for the patient. This amount is boosted to about 30-35% by nasal cannula. In case 100% is required, it is delivered to the patient’s body by a tight-fitting mask. Petersburg applies three methods of storage of this gas: liquid gas storage tanks, compressed gas storage tanks, and instant usage. The supply ducts pose a great fire risk due to the rapid combustion of oxygen. Patients require time to relax outside in the open, away from their rooms every now and then. It’s the duty of the nurses to decide when and where it is perfectly safe for them to do so. At times the wheelchairs are provided to aid in the process. In addition, there are set visiting hours for the patients. The normal visiting hours begin at 7.00 am and end at 10.00 pm in the evening. These are meant to provide the patient with the emotional support that could fasten their healing. The majority of the activities in the hospital req