Digital Commons Network^™

Medical Marijuana, Taxation, And Internal Revenue Code Section 280e, Douglas A. Kahn, Howard J. Bromberg

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Congress enacted § 280E of the Internal Revenue Code in 1982 to punish businesses engaged in illegal drug trafficking, including marijuana. Section 280E denies all credits and deductions, including ordinary business expenses, from gross income of businesses illegally trafficking in a Schedule I or II controlled substance. This provision violates the principle that the tax code should foster a consistent treatment of income, regardless of source; and that the income tax is ill-used for punitive measures. Now that marijuana has been legalized in some form in at least 46 states for therapeutic purposes, this federal tax penalty transgresses principles of …

Modulation Of Medical Condition Likelihood By Patient History Similarity, Jonathan Turner, Dympna O'Sullivan, Jon Bird

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Introduction: We describe an analysis that modulates the simple population prevalence derived likelihood of a particular condition occurring in an individual by matching the individual with other individuals with similar clinical histories and determining the prevalence of the condition within the matched group.

Methods: We have taken clinical event codes and dates from anonymised longitudinal primary care records for 25,979 patients with 749,053 recorded clinical events. Using a nearest neighbour approach, for each patient, the likelihood of a condition occurring was adjusted from the population prevalence to the prevalence of the condition within those patients with the closest matching clinical …

On The Socles Of Fully Inert Subgroups Of Abelian P-Groups, Andrey R. Chekhlov, Peter V. Danchev, Brendan Goldsmith

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We define the so-called fully inert socle-regular and weakly fully inert socle-regular Abelian p-groups and study them with respect to certain of their numerous interesting properties. For instance, we prove that in the case of groups of length ! these two group classes coincide but that in the case of groups of length ! + 1 they differ. Some structural and characterization results are also obtained. The work generalizes concepts which have been of interest recently in the theory of entropy in algebra and builds on recent investigations by the second and third named authors in Arch. Math. Basel (2009) …

A Proposal Digital Marketing Strategy For Marcheluzzo Srl: Training And Evaluating A Prediction Model For The Number Of Adv. Impressions, Charles Alves De Castro

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This research aims to describe a digital marketing strategy elaborated to be deployed in the MarcheluzzoSrl Company located in Italy. In addition, it intends to give a wide range of information to the company about its customers, target, competitors, market, digital marketing strategy, and potential recommendations. It is also important to highlight that this strategy is focused on the Brazilian market. Most of the information collected for the situational analysis and many other components for this research were gathered through the author`s perception during his internship in the company. The methodology includes secondary data collected through field observation in the …

The Neglect Of Persons With Severe Brain Injury To The United States: An International Human Rights Analysis, Tamar Ezer, Megan S. Wright, Joseph J. Wright

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Brain injury contributes more to death and disability globally than any other traumatic incident. While the past decade has seen significant medical advances, laws and policies remain stumbling blocks to treatment and care. The quality of life of persons with severe brain injury often declines with unnecessary institutionalization and inadequate access to rehabilitation and assistive technologies. This raises a host of rights violations that are hidden, given that persons with severe brain injury are generally invisible and marginalized. This article highlights the current neglect and experiences of persons with severe brain injury in the United States, analyzing the rights to …

On The Relationship Between Developer Experience And Refactoring: An Exploratory Study And Preliminary Results, Eman Abdullah Alomar, Anthony Peruma, Christian D. Newman, Mohamed Wiem Mkaouer, Ali Ouni

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Refactoring is one of the means of managing technical debt and maintaining a healthy software structure through enforcing best design practices, or coping with design defects. Previous refactoring surveys have shown that these code restructurings are mainly executed by developers who have sufficient knowledge of the system’s design, and disposing of leadership roles in their development teams. However, these surveys were mainly limited to specific projects and companies. In this paper, we explore the generalizability of the previous results though analyzing 800 open-source projects. We mine their refactoring activities, and we identify their corresponding contributors. Then, we associate an expertise …

Disability And Reproductive Justice, Samuel Bagenstos

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In the spring of 2019, disability and abortion rights collided at the Supreme Court in a case involving an Indiana ban on “disability-selective abortions.” In a lengthy concurrence in the denial of certiorari, Justice Thomas argued that the ban was constitutional because it “promote[s] a State’s compelling interest in preventing abortion from becoming a tool of modern-day eugenics.” Just a few months earlier, disability and reproductive rights issues had intersected in a very different way in the debate over the nomination of Brett Kavanaugh to the Supreme Court. Disability rights advocates drew attention to an opinion then-Judge Kavanaugh had written …

Sharp Lines And Sliding Scales In Tax Law, Edward Fox, Jacob Goldin

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The law is full of sharp lines, where small changes in one’s circumstances lead to significant changes in legal treatment. In many cases, a sharp line can be smoothed out by replacing it with a sliding scale. Under a sliding scale, small changes in one’s circumstances lead to small changes in legal treatment. In this paper, we study the policy choice between sharp lines and sliding scales in tax law. We focus on considerations relating to efficiency, complexity, administration, tax planning, and the objectives of specific provisions. Although sharp lines are currently widespread in tax law, we argue that sliding …

Commonsense Consent, Roseanna Sommers

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Consent is a bedrock principle in democratic society and a primary means through which our law expresses its commitment to individual liberty. While there seems to be broad consensus that consent is important, little is known about what people think consent is. This Article undertakes an empirical investigation of people’s ordinary intuitions about when consent has been granted. Using techniques from moral psychology and experimental philosophy, it advances the core claim that most laypeople think consent is compatible with fraud, contradicting prevailing normative theories of consent. This empirical phenomenon is observed across over two dozen scenariosspanning numerous contexts in which …

Why R&D Should Be Allocated To Subpart F And Gilti, Stephen E. Shay, Reuven S. Avi-Yonah, Patrick Driessen, J. Clifton Fleming Jr., Robert J. Peroni

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This article responds to the notice of proposed rulemaking under sections 861 and 904 (REG105495-19) published in the Federal Register December 17, 2019 (the proposed regulations). The proposed regulations would not allocate U.S. shareholder deductions for research and development or experimentation (R&D or R&E) expenditures under section 174 (R&D deductions) to a gross income inclusion under section 951 (subpart F inclusion) or section 951A (global intangible low-taxed income)1 from a controlled foreign corporation for foreign tax credit limitation purposes.

May The State Punish What It May Not Prevent?, Gabriel S. Mendlow

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In Why Is It Wrong To Punish Thought? I defended an overlooked principle of criminalization that I called the Enforceability Constraint. The Enforceability Constraint holds that the state may punish transgressions of a given type only if the state in principle may forcibly disrupt such transgressions on the ground that they are criminal wrongs. As I argued in the essay, the reason why the state is forbidden from punishing thought is that the state is forbidden from forcibly disrupting a person’s mental states on the ground that they are criminally wrongful (as opposed to, say, on the ground that they …

Asynchronous Assistance: A Social Network Analysis Of Influencing Peer Interactions In Peerwise, Tomas Shields, Geraldine Gray, Barry J. Ryan

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This mixed methods, investigative case study explored student patterns of use within the online PeerWise platform to identify the most influencing activities and to build a model capable of predicting performance based on these influencing activities. Peerwise is designed to facilitate student peer-to-peer engagement through creating, answering and ranking multiple choice questions; this study sought to understand the relationship between student engagement in Peerwise and learning performance. To address the research question, various usage metrics were explored, visualized and modelled, using social network analysis with Gephi, Tableau and Python. These findings were subsequently analyzed in light of the qualitative survey …

The Eighth Amendment Power To Discriminate, Kathryn E. Miller

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For the last half-century, Supreme Court doctrine has required that capital jurors consider facts and characteristics particular to individual defendants when determining their sentences. While liberal justices have long touted this individualized sentencing requirement as a safeguard against unfair death sentences, in practice the results have been disappointing. The expansive discretion that the requirement confers on overwhelmingly White juries has resulted in outcomes that are just as arbitrary and racially discriminatory as those that existed in the years before the temporary abolition of the death penalty in Furman v. Georgia.' After decades of attempting to eliminate the requirement, conservative justices …

Raman Spectroscopy Of Lymphocytes For The Identification Of Prostate Cancer Patients With Late Radiation Toxicity Following Radiotherapy, Daniel Cullen, Jane Bryant, Adrian Maguire, Denish Medipally, Brendan Mcclean, Laura Shields, Emma Noone, Shirley Bradshaw, Marie Finn, Mary Dunne, Aoife M .Shannon, John Armstrong, Orla Howe, Aidan Meade, Fiona Lyng

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The success of radiotherapy in tumour control depends on the total dose given. However, the tolerance of the normal tissues surrounding the tumour limits this dose. It is not known why some patients develop radiation toxicity and, currently, it is not possible to predict before treatment which patients will experience adverse effects. Thus, there is an unmet clinical need for a new test to identify patients at risk of radiation toxicity. Here, we report a new approach based on Raman spectroscopy.Blood samples were collected from 42 patients who had undergone radiotherapy for prostate cancer and had shown either severe or …

Who Gets The Ventilator? Disability Discrimination In Covid-19 Medical-Rationing Protocols, Samuel Bagenstos

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The coronavirus pandemic has forced us to reckon with the possibility of having to ration life-saving medical treatments. In response, many health systems have employed protocols that explicitly de-prioritize people for these treatments based on pre-existing disabilities. This Essay argues that such protocols violate the Americans with Disabilities Act, the Rehabilitation Act, and the Affordable Care Act. Such explicit discrimination on its face violates these statutes. Nor can medical providers simply define disabled patients as being “unqualified” because of disabilities that do not affect the ability to ameliorate the condition for which treatment is sought. A proper interpretation of the …

Alzheimer's Disease: The Link Between Amyloid-Β And Neurovascular Dysfunction., Ernesto Solis, Kevin N Hascup, Erin R Hascup

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While prevailing evidence supports that the amyloid cascade hypothesis is a key component of Alzheimer's disease (AD) pathology, many recent studies indicate that the vascular system is also a major contributor to disease progression. Vascular dysfunction and reduced cerebral blood flow (CBF) occur prior to the accumulation and aggregation of amyloid-β (Aβ) plaques and hyperphosphorylated tau tangles. Although research has predominantly focused on the cellular processes involved with Aβ-mediated neurodegeneration, effects of Aβ on CBF and neurovascular coupling are becoming more evident. This review will describe AD vascular disturbances as they relate to Aβ, including chronic cerebral hypoperfusion, hypertension, altered …

Does Sars-Cov-2 Infection Cause Chronic Neurological Complications?, Erin R Hascup, Kevin N Hascup

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The current pandemic caused by severe acute respiratory syndrome coronavirus (SARS-CoV)-2 has created an unparalleled health crisis. Besides the acute respiratory infection, CoVs are neuroinvasive causing additional inflammation and neurodegeneration. This is likely also true of SARS-CoV-2 given reports of neurological manifestations in coronavirus disease 2019 (COVID-19) positive patients. Older adults > 65 years of age constitute a high-risk group prone to severe infection and death. Despite the higher mortality rate, a majority of cases are expected to recover and survive from this viral outbreak. But, the long-term consequences of SARS-CoV-2 neuroinfection are unknown. We discuss these potential chronic changes to …

Rapid Restoration Techniques For Software-Defined Networks, Ali Malik, Ruairí De Fréin, Benjamin Aziz

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There is increasing demand in modern day business applications for communication networks to be robust and reliable due to the complexity and critical nature of such applications. As such, data delivery is expected to be reliable and secure even in the harshest of environments. Software-Defined Networking (SDN) is gaining traction as a promising approach for designing network architectures which are robust and flexible. One reason for this is that separating the data plane from the control plane, increases the controller’s ability to configure the network rapidly. When network failure events occur, the network manager may trade-off the optimality of the …

Fabrication Of Polymer Monoliths Within The Confines Of Non-Transparent 3d-Printed Polymer Housings, Noor Abdulhussain, Suhas H. Nawada, Sinéad Currivan, Marta Passamonti, Peter J. Schoenmakers

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In the last decade, 3D-printing has emerged as a promising enabling technology in the field of analytical chemistry. Fused-deposition modelling (FDM) is a popular, low-cost and widely accessible technique. In this study, RPLC separations are achieved by in-situ fabrication of porous polymer monoliths, directly within the 3D-printed channels. Thermal polymerization was employed for the fabrication of monolithic columns in optically non-transparent column housings, 3D-printed using two different polypropylene materials. Both acrylate-based and polystyrene-based monoliths were created. Two approaches were used for monolith fabrication, viz. (i) in standard polypropylene (PP) a two-step process was developed, with a radical initiated wall-modification step …

An Application Of Machine Learning To Explore Relationships Between Factors Of Organisational Silence And Culture, With Specific Focus On Predicting Silence Behaviours, Stephen Barrett Dr

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Research indicates that there are many individual reasons why people do not speak up when confronted with situations that may concern them within their working environment. One of the areas that requires more focused research is the role culture plays in why a person may remain silent when such situations arise. The purpose of this study is to use data science techniques to explore the patterns in a data set that would lead a person to engage in organisational silence. The main research question the thesis asks is: Is Machine Learning a tool that Social Scientists can use with respect …

Importing Prescription Drugs From Canada — Legal And Practical Problems With The Trump Administration's Proposal, Rachel E. Sachs, Nicholas Bagley

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As Americans report ever-growing difficulty affording their prescription drugs, President Donald Trump has come under increasing pressure to act. To date, the Trump administration has attempted to advance a number of policy initiatives by means of executive action, but it has not yet adopted a program that would meaningfully assist patients. Most recently, the administration proposed a rule that, if finalized, would allow states to develop programs to import lower-priced prescription drugs from Canada, with the intent of reducing spending on drugs by U.S. patients and states and increasing access for patients.

Ultrasound-Assisted Extraction Of Polyphenols From Ginger (Zingiber Officinale) And Evaluation Of Its Antioxidant And Antimicrobial Properties, Amy Murphy, Eilish Norton, Faye Montgomery, Amit Jaiswal, Swarna Jaiswal

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In this present study, ultrasound-assisted solvent extraction conditions were optimized to develop a more efficient method that would result in maximum extraction of polyphenols from ginger. To achieve this optimal extraction process, a central composite design of response surface methodology was applied. A second-order polynomial equation was developed, indicating the effect of ginger concentration (400-1,200 mg/20mL solvent), solvent mixture composition (20-100%), temperature (30-70°C) and treatment time (10-30 min) on polyphenols extraction. The optimum parameters were found to be 1200mg of ginger prepared with 86% ethanol and sonication for 11 minutes at 65°C. The total phenolic and flavonoid content of ginger …

Assessing The Market Niche Of Eurasian Rail Freight In The Belt And Road Era., Xu Zhang, Hans-Joachim Schramm

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This paper presents an overview of the recent development of Eurasian rail freight in the Belt and Road era and further evaluates its service quality in terms of transit times and transport costs compared to other transport modes in containerised supply chains between Europe and China.

A trade-off model of transit time and transport costs based on quantitative data from primary and secondary sources is developed to demonstrate the market niche for Eurasian rail freight vis-a-vis the more established modes of transport of sea, air, and sea/air. In a scenario analysis, further cargo attributes influencing modal choice are employed to …

The Grammatical Class Effect Is Separable From The Concreteness Effect In Language Learning, Katherine I. Martin, Natasha Tokowicz

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Typically concrete words are learned better than abstract words (Kaushanskaya & Rechtzigel, 2012), and nouns are learned better than verbs (Kauschke & Stenneken, 2008). However, most studies on concreteness have not manipulated grammatical class (and vice versa), leaving the relationship between the two unclear. Therefore, in two experiments we examined the effects of grammatical class and concreteness simultaneously in foreign language vocabulary learning. In Experiment 1, English speakers learned ‘foreign language’ words (English pseudowords) mapped to concrete and abstract nouns and verbs. In Experiment 2, English speakers learned German words with the same procedure. Overall, the …

A Generalisable Bottom-Up Methodology For Deriving A Residential Stock Model From Large Empirical Databases., Ciara Ahern, Brian Norton

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Average reference dwellings representing a predominant housing typology are defined in this work. Specifying such reference buildings is a prerequisite for (i) calculating cost-optimal energy performance requirements for buildings and building elements and (ii) ensuring valid calculations of national building energy consumption. In the EU, an Energy Performance Certificate (EPC) rating is an assessment of the energy consumption of a dwelling. The use of inappropriate default-values for the building envelope thermal transmittance coefficients (U-values) and standardised thermal bridging transmittance coefficients (Y-values) in the production of EPCs leads to an over-estimation of potential energy savings from interventions in the existing dwelling …

Toward The Automatic Classification Of Self-Affirmed Refactoring, Mohamed Wiem Mkaouer, Eman Abdullah Alomar, Ali Ouni

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The concept of Self-Affirmed Refactoring (SAR) was introduced to explore how developers document their refactoring activities in commit messages, i.e., developers explicit documentation of refactoring operations intentionally introduced during a code change. In our previous study, we have manually identified refactoring patterns and defined three main common quality improvement categories including internal quality attributes, external quality attributes, and code smells, by only considering refactoring-related commits. However, this approach heavily depends on the manual inspection of commit messages. In this paper, we propose a two-step approach to first identify whether a commit describes developer-related refactoring events, then to classify it according …

How Do Developers Refactor Code To Improve Code Reusability?, Eman Abdullah Alomar, Philip T. Rodriguez, Jordan Bowman, Tianjia Wang, Benjamin Adepoju, Kevin Lopez, Christian D. Newman, Ali Ouni, Mohamed Wiem Mkaouer

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. Refactoring is the de-facto practice to optimize software health. While there has been several studies proposing refactoring strategies to optimize software design through applying design patterns and removing design defects, little is known about how developers actually refactor their code to improve its reuse. Therefore, we extract, from 1,828 open source projects, a set of refactorings which were intended to improve the software reusability. We analyze the impact of reusability refactorings on state-of-the-art reusability metrics, and we compare the distribution of reusability refactoring types, with the distribution of the remaining mainstream refactorings. Overall, we found that the distribution of …

An Exploratory Study On How Software Reuse Is Discussed In Stack Overflow, Mohamed Wiem Mkaouer, Eman Abdullah Alomar, Jiaqian Liu, Ali Ouni, Christian D. Newman, Diego Barinas

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Software reuse is an important and crucial quality attribute in modern software engineering, where almost all software projects, open source or commercial, no matter small or ultra-large, source code reuse in one way or another. Although software reuse has experienced an increased adoption throughout the years with the exponentially growing number of available third-party libraries, frameworks and APIs, little knowledge exists to investigate what aspects of code reuse developers discuss. In this study, we look into bridging this gap by examining Stack Overflow to understand the challenges developers encounter when trying to reuse code. Using the Stack Overflow tags “code-reuse” …

How We Refactor And How We Document It? On The Use Of Supervised Machine Learning Algorithms To Classify Refactoring Documentation, Eman Abdullah Alomar, Anthony Peruma, Mohamed Wiem Mkaouer, Christian D. Newman, Marouane Kessentini, Ali Ouni

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Refactoring is the art of improving the structural design of a software system without altering its external behavior. Today, refactoring has become a well-established and disciplined software engineering practice that has attracted a significant amount of research presuming that refactoring is primarily motivated by the need to improve system structures. However, recent studies have shown that developers may incorporate refactoring strategies in other development-related activities that go beyond improving the design especially with the emerging challenges in contemporary software engineering. Unfortunately, these studies are limited to developer interviews and a reduced set of projects. To cope with the above-mentioned limitations, …

Writing And Well-Being: Story As Salve In The Work Of (More Than) Two Updikes, Sue Norton

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No abstract provided.