gebhart/patrepeval huggingface dataset:
Penalty Protection Opinions and Advisor Conflicts of Interest (2012)

This article considers when a taxpayer should not be able to rely on a tax opinion to avoid penalties when the tax advisor rendering the opinion has an apparent conflict of interest. The article has three parts. The first part describes the statutory and regulatory standards for taxpayers seeking to rely on tax advice to avoid penalties. The second part of the article describes the cases where a taxpayer has sought to rely on the opinion of a tax advisor with a conflict of interest. Those cases involve three types of situations: (1) tax advisors acting as promoters or brokers of a tax shelter; (2) tax advisors with referral arrangements with tax shelter promoters; and (3) tax advisors that are developers or implementers of a tax strategy. The third part of the article proposes a framework for analyzing how a conflict of interest may affect the reliability of a tax advisor's opinion. It first argues that the analysis should not apply a per se rule, but rather should determine reasonableness and good faith from the perspective of what the taxpayer knew or should have known of the tax advisor's conflict and how the conflict may have affected the reliability of the opinion. In the absence of a per se rule, a court first should consider whether a conflict is relevant to the reliability of the opinion. If the conflict is relevant, the court should consider both (1) the inducement that the apparent conflict may have created to distort the advice (temptation), and (2) the advisor's apparent response to such inducement (resistance). These two variables can be used to create a framework where the level of apparent temptation is compared to the level of apparent resistance. Thus, for example, a court should be more vigilant in case involving a high level of apparent temptation and a low level of apparent resistance, than in a case involving a low level of apparent temptation and a high level of apparent resistance. Finally, the article explores common forms of temptation that tax advisors face when advising on tax-motivated transactions, and considers the circumstances when an advisor's response to those temptations can make an opinion unreliable.
Post-Thaw Viable CD45+ Cells and Clonogenic Efficiency are Associated with Better Engraftment and Outcomes after Single Cord Blood Transplantation in Adult Patients with Malignant Diseases (2015)

The quantity of cells is widely accepted as the main factor influencing the outcome after umbilical cord blood transplantation (UCBT) however, the quality of the cord blood units (CBUs) has been less studied. In order to determine the impact of qualitative variables in UCBT outcomes, we conducted a multicenter retrospective study in adult patients with hematological malignancies who underwent single UCBT after a common myeloablative conditioning regimen. One hundred and ten patients from 3 institutions [median age, 35 years (range 18-55)] were included. Quantitative (TNC and total CD34+cells) and qualitative variables [viable CD45+ (vCD45+), vCD34+ and clonogenic efficiency [(CLONE), quotient of post-thaw colony-forming units (CFU)] and pre-freeze CD34+ cells predicted engraftment in univariate analysis however, only 2 qualitative variables remained significant in the multivariate analysis. Infusion of more than 2 × 10(7) post-thaw vCD45+ cells per kilogram was significantly associated with faster neutrophil (P = .01), platelet engraftment (P = .01), higher disease-free (P = .01) and overall survival (0.02). In addition, CLONE ≥ 20% predicted a faster neutrophil (P = .005), platelet engraftment (P = .01) and contributed to decrease the non-relapse mortality (P = .02). Our study suggests that the vCD45+ cells dose and CLONE are powerful surrogate markers of graft quality and can potentially help on CBUs selection if tested with representative reference samples.
Selective fluorometric detection of pyrophosphate by interaction with alizarin red S–dimethyltin(iv) complex (2011)

Highly selective detection of pyrophosphate in the presence of inorganic phosphate, halides, acetate, ATP, other nucleotides and phosphate esters in neutral aqueous solutions is achieved by using fluorescent dimethyltin(iv)-alizarin red S complex.
GCQ - A Universal Gaseous Fuel Composition and Quality Sensor (1993)

<div class="htmlview paragraph">Studies of the physical and combustion properties of saturated hydrocarbon gaseous fuels have shown that there is a remarkable correlation between these properties and the hydrogen to carbon ratio of the fuel molecules. If the correlation is limited to the four most prevalent constituents of natural gas fuels, i.e., methane (CH<sub>4</sub>), ethane (C<sub>2</sub> H<sub>6</sub>), propane (C<sub>3</sub>H<sub>8</sub>) and butane (C<sub>4</sub>H<sub>10</sub>), it appears that the flow and combustion characteristics of the pure gases and mixtures of these same gases can be predicted from the H/C ratio alone, independent of the various proportions of the gases. It was concluded that if the H/C ratio of a mixture of gases could be determined by means of an on-line dynamic sensor, important engine and fuel management parameters, such as octane no., methane no., density, stoichiometric air/fuel ratio, etc. could be determined and compensated for by an electronic control unit. Such a sensor has been designed, demonstrated and used as an input to an electronic engine control unit. The software of the electronic control unit of a fuel management system can make adjustments to instantly compensate for variations in fuel composition and quality.</div>
Implementation of security framework for multiple web applications (2014)

Single sign-on (SSO) is an identity management technique that provides users the ability to use multiple Web services with one set of credentials. However, when the authentication server is down or unavailable, users cannot access Web services, even if the services are operating normally. Therefore, enabling continuous use is important in single sign on. In this paper, we present security framework to overcome credential problems of accessing multiple web application. We explain system functionality with authorization and Authentication. We consider these methods from the viewpoint of continuity, security and efficiency makes the framework highly secure.
Rational Design of an Indolebutanoic Acid Derivative as a Novel Aldose Reductase Inhibitor Based on Docking and 3D QSAR Studies of Phenethylamine Derivatives (2003)

A series of 45 phenethylamine derivatives were synthesized and evaluated for their inhibitory activity against pig kidney aldose reductase (ALR2, EC 1.1.1.21). Their IC(50) values ranged from 400 microM to 24 microM. The binding modes of compounds at the active site of ALR2 were examined using flexible docking. The results indicated that phenethylamine derivatives nicely fit into the active pocket of ALR2 by forming various hydrogen bonding and hydrophobic interactions. 3D-QSAR analysis was also conducted using FlexX-docked alignment of the compounds. The best prediction was obtained by CoMSIA combined with hydrophobic and hydrogen bond donor/acceptor field (q(2) = 0.557, r(2) = 0.934). A new derivative, 4-oxo-4-(4-hydroxyindole)butanoic acid, was designed, taking into account the CoMSIA field and the binding mode derived by FlexX docking. This rationally designed compound exhibits an ALR2 inhibition with an IC(50) value of 7.4 microM, which compares favorably to that of a well-known ALR2 inhibitor, tolrestat (IC(50) = 16 microM) and represents a potency approximately 240-fold higher than that of an original phenethylamine lead compound, YUA001.
Mg 이 상용 주철의 계면편석에 미치는 영향 (1993)

The segregation established at the interfaces of gray and ductile iron has been examined by using Auger electron spectroscopy. This work pursued the effect of Mg on the interface chemistry as a first step to understand the microstructural modification caused by the doping addition of Mg into cast iron melts. In gray iron, S was the major segregant to both the iron/graphite and iron/iron interfaces. The effect of Mg in ductile iron was demonstrated by the clean interfaces with no such impurity segregation as observed in gray iron. Oxygen segregation was not significant at both the gray and ductile iron interfaces contrary to the results of ocher works. The segregation at, the iron/iron interface greatly supported the results obtained from the iron/graphite interface, especially with regrad to the controversial O segregation and also the segregation behavior of S as affected by Mg.
Synthesis and characterization of fluorene‐based low‐band gap copolymers containing propylenedioxythiophene and benzothiadiazole derivatives for bulk heterojunction photovoltaic cell applications (2008)

Abstract The following noble series of soluble π‐conjugated statistical copolymers was synthesized by palladium catalyzed Suzuki polymerization: poly[(9,9‐dioctylfluorene)‐ alt ‐(4,7‐bis(3′,3′‐dihepyl‐3,4‐propylenedioxythienyl)‐2,1,3‐benzothiadiazole)] (PFO‐PTBT) derived from poly(9,9‐dioctylfluorene) (PFO) and poly[(4,7‐bis(3′,3′‐dihepyl‐3,4‐propylenedioxythienyl)‐2,1,3‐benzothiadiazole)] poly(heptyl 4 ‐PTBT). The structure and properties of these polymers were characterized using 1 H‐, 13 C‐NMR, UV–visible spectroscopy, elemental analysis, GPC, DSC, TGA, photoluminescence (PL), and cyclic voltammetry (CV). The statistical copolymers, PFO‐PTBT (9:1, 8.4:1.6, 6.5:3.5), were soluble in common organic solvents and easily spin coated onto indium‐tin oxide (ITO) coated glass substrates. The weight‐average molecular weight ( M w ) and polydispersity of the PFO‐PTBT ranged from (1.0–4.2) × 10 4 and 1.5–2.3, respectively. Bulk heterojunction photovoltaic cells with an ITO/PEDOT/PFO‐PTBT:PCBM/LiF/Al configuration were fabricated, and the devices using PFOPTBT (6.5:3.5) showed the best performance compared with those using PFO‐PTBT (9:1, 8.4:1.6). A maximum power conversion efficiency (PCE) of 0.50% ( V oc = 0.66 V, FF = 0.29) was achieved with PFO‐PTBT (6.5:3.5). © 2008 Wiley Periodicals, Inc. J Polym Sci Part A: Polym Chem 46: 6175–6184, 2008
Delivery risk and the hedging role of options (2002)

Abstract Multiple delivery specifications exist on nearly all commodity futures contracts. Sellers typically are allowed to deliver any of several grades of the underlying commodity and at any of several locations. On the delivery day, the futures price as such needs not converge to the spot price of the par‐delivery grade at the par‐delivery location, thereby imposing an additional delivery risk on hedgers. This article derives the optimal hedging strategy for a risk‐averse hedger in the presence of delivery risk. In particular, it is shown that the hedger optimally uses options on futures for hedging purposes. This article provides a rationale for the hedging role of options when futures markets allow for multiple delivery specifications. © 2002 Wiley Periodicals, Inc. Jrl Fut Mark 22:339–354, 2002
Learning Progressions in Science: An Evidence-based Approach to Reform (2009)

principal investigator of the Center on Continuous Instructional Improvement (CCII). Corcoran's research interests include strategies for improving instruction, the use of research ndings and clinical
Classification of breast cancer histopathological images using interleaved DenseNet with SENet (IDSNet) (2020)

In this study, we proposed a novel convolutional neural network (CNN) architecture for classification of benign and malignant breast cancer (BC) in histological images. To improve the delivery and use of feature information, we chose the DenseNet as the basic building block and interleaved it with the squeeze-and-excitation (SENet) module. We conducted extensive experiments with the proposed framework by using the public domain BreakHis dataset and demonstrated that the proposed framework can produce significantly improved accuracy in BC classification, compared with the state-of-the-art CNN methods reported in the literature.
Luminescent square-planar platinum(ii) complexes with tridentate 3-bis(2-pyridylimino)isoindoline and monodentate N-heterocyclic ligands (2011)

A series of platinum(II) complexes with 1,3-bis(2-pyridylimino)isoindoline (BPI) derivatives were prepared by substitution of the coordinated Cl in the precursor complex Pt(BPI)Cl with a N-heterocyclic ligand such as pyridine, phthalazine or phenanthridine. These complexes display orange to red luminescence in fluid dichloromethane solutions and in the solid states at room temperature. The photophysical properties were tuned by introducing electron-withdrawing -NO(2) or electron-donating -NH(2) to the BPI ligand. The DFT computational studies suggest that the emission in the N-heterocyclic ligand substituted platinum(II) complexes originates mainly from the (3)[π→π*(BPI)] (3)IL triplet excited state, mixed with some (3)[dπ(Pt)→π*(BPI)] (3)MLCT character. Compared with the precursor Pt(BPI)Cl, both the low-energy absorption and the emission in the N-heterocyclic ligand substituted platinum(II) complexes exhibits a distinct blue-shift due to an obviously enhanced contribution from the (3)IL state and a reduced (3)MLCT character.
A reconfigurable modem for increased network capacity and video, voice, and data transmission over GSM PCS (1996)

A reconfigurable global mobile standard (GSM) compatible radio modem interface which doubles the number of simultaneous video and voice transmissions per channel is presented for personal communication systems (PCSs). The result is that an average video frame rate of up 14 frames per second (fps) can be supported within a single TDMA time slot, doubling the number of conventional GMSK multimedia transmissions per GSM channel. The design employs an in-circuit reconfigurable (ICR) cross-correlated Feher's (see Englewood Cliffs, NJ: Prentice-Hall, 1995). quadrature phase shift keyed (FQPSK) signal processing technique to support a data rate of 357.5 kb/s in a 200 kHz bandlimited GSM channel. This innovative new network modem is reconfigured in-circuit for high bit rate data transmission or voice operation that is compatible with existing GSM equipment. Spectrum efficiency /spl eta//sub f/ (b/s/Hz) is investigated in a nonlinear amplified (NLA) environment-providing a 6 to 9 dB advantage in power efficiency for increased battery life of hand-held terminals. Results show that RF power efficient nonlinear amplified spectrum efficiency is increased from 1.35 b/s/Hz to 1.85 b/s/Hz. Bit error rate (BER) performance is evaluated in a Gaussian and Rayleigh fading channel, and the merits of coherent demodulation in microcellular PCS are examined. Our results show that the GSM compatible configuration of a specific cross correlated FQPSK-KF implementation offers up to 2 dB improvement in E/sub b//N/sub 0/ over conventional GMSK BT/sub b/=0.3. The PCS network capacity /spl eta//sub T/ (Erlangs/Hz m/sup 2/) may be increased 37% over GMSK BT/sub b/=0.3.
Maskless implants of 20 keV Ga+ in thin crystalline silicon on insulator (2013)

A nano-sized ion beam apparatus has been used as maskless lithography to implant 20 keV Ga+ ions into a 26 nm thick silicon crystalline film on insulator. The ion beam, with about 5 nm standard deviation, delivered few hundred ions during a single shot. Circular areas with nominal diameter of 20 or 50 nm were irradiated to a fluence of 5 × 1014/cm2. Transmission electron microscopy evidenced that the damaged regions are characterized by an irregular contour with many disordered filaments. Damage extends across the layer thickness and fast Fourier transform analysis indicates that implantation causes the amorphization of a region which extends beyond the nominal diameter. In situ annealing experiments demonstrated that the disordered filamentary regions disappear in the 250–450 °C temperature range and the interfaces with the surrounding crystalline regions sharpen. A temperature as high as 600 °C is required to fully re-crystallize the amorphous core of the implanted dots. Reordering occurs by multi-orientation lateral solid-phase epitaxial growth and the breaking of (111) and (101) interfaces, due to the formation of twins, triggers a fast crystallization kinetics. Rapid thermal annealing (890 °C-10 s) completely crystallizes the amorphous regions, twins are absent and small cluster of defects remains instead. Preliminary scanning capacitance measurements indicate that the implanted atoms, after crystallization, are electrically active. The implant method is then a viable processing step for the doping of non-bulk fully depleted ultra-thin-body MOSFET.
The Right to Participate and the Right to Know in Montana (2005)

The right-of-participation and right-to-know sections of the Montana Constitution encourage open government and maximize citizen access to the decision-making institutions of state and local government.Both rights enhance the freedom of information which is the cornerstone of democracy.The right-ofparticipation section was a response to insider deal-making in state and local government. 2 The right-to-know section was a response to the penchant for secrecy in government by state and local officials. 3 Government is derived from the people and is intended for the benefit of the people.The people have a right to demand information about government activities and to obtain the information they request.Government in Montana is more open and accessible because of these two very important
When should a cervical collar be used to treat neck pain? (2007)

Neck pain is one of the most prevalent and costly health problems in the United States. It remains a complex, subjective experience with a variety of musculoskeletal causes. Although, cervical collars are a seemingly benign intervention, they can have adverse effects, especially when used for longer periods of time. It is feared that a long period of immobilization, can result in atrophy-related secondary damage. Many physicians cite anecdotal evidence of their clinical utility and soft cervical collars are often prescribed by convention for patients complaining of neck pain. The use of cervical collars to treat neck pain is an area of controversy. This review article examines the current evidence and studies related to recommending cervical collars for neck pain of a variety of etiologies.
Weather Shocks, Iowa Agriculture, and Agricultural Policy (2015)

Volatility in Iowa agriculture, especially in yields and prices of corn and soybeans, has been increasing over time and indications are that increases in volatility are likely to continue in the future. Two primaTy reasons u nderlie probable increases in this volatility: (1) Increasing yields through plant development implies that regional weather shocks have an increasing effect on production supply, and (2) Levels of buller stocks are so low that there are limited price stabilization effects due to changes in stockholdings. Figure l shows historical yields for Iowa corn and illustrates that yield deviations have been steadily increasing over time. Stocks-to-use ratios presented in Table 1 show declines in projected values.
Fitness monitoring system based on heart rate and SpO2 level (2010)

The paper presents CaszOxiSys, a real-time system for monitoring and analyzing physiological signals during fitness activity. CaszOxiSys consists of non-invasive pair of physiological sensor (light-emitting diode & photodiode) wirelessly connected through Bluetooth to a netbook or laptop which analyses physiological data and presents it to the user in an intelligible and informative way. This paper focuses on an implementation of CaszOxiSys using a pulse oximeter to monitor the user's heart rate and oxygen saturation. This paper also describes, the Karvonen formula which calculates the target heart rate zone based on age, gender, resting heart rate, maximum heart rate, and fitness intensity level. The Karvonen formula acts as a guideline for fitness workout sessions. The proposed system works in a client-server architecture, where the clients system is used by the fitness center users and the server system is the central monitoring system(s) used by the fitness trainers. The paper also explains how physiological data is transmitted and describes the structure of the transmitted data between the pulse oximeter, client system and server system. CaszOxiSys provides a complete monitoring solution for fitness centers, allowing fitness trainers to monitor the fitness center users from a central or mobile location.
The biology of <i>Myxosoma cerebralis:</i> the causative organism of whirling disease of salmonids (1976)

The literature describing the biology and control of Myxosoma cerebralis (whirling disease) is reviewed. New data on the world distribution of the parasite are presented. It is concluded that the presence of M. cerebralis is not an important limiting factor in salmonid fanning per se but only limits methods of production.
Identity and function of γ‐secretase (2003)

gamma-Secretase catalyzes intramembrane proteolysis of various type I membrane proteins, including the amyloid-beta precursor protein and the Notch receptor. Despite its importance in the pathogenesis of Alzheimer's disease and to normal development, this protease has eluded identification until only very recently. Four membrane proteins are now known to be members of the protease complex: presenilin, nicastrin, aph-1, and pen-2. Recent findings suggest that these four proteins are sufficient to reconstitute the active gamma-secretase complex and that together they mediate the cell surface signaling of a variety of receptors via intramembrane proteolysis.