Digital Commons Network^™

International And Foreign Tax Research, Jason Zarin

Law Faculty Publications

Tax research often strikes fear in the heart of lawyer and librarian alike, and foreign and international tax research, doubly-so. Fortunately, the resources available for tax research are top-notch, which should enable your research to proceed painlessly.

This article will look at resources and tools for finding model and in-force bilateral tax treaties; foreign tax law in both English and vernacular; and newsletters for keeping abreast of current issues in international and foreign tax law.

The Secret Economy Of Charitable Giving, Allison Anna Tait

Law Faculty Publications

Charitable giving is big business. In 2009, the Internal Revenue Service reported close to 100,000 private foundations, almost double the number from fifteen years earlier. Some of these charitable trusts, like the Gates Foundation, are multi-billion dollar enterprises. Trust instruments and other governing documents set forth the terms that control these gifts. Because charitable trusts can exist in perpetuity, however, changing circumstances sometimes render the terms difficult to fulfill. Courts can apply cy pres, a doctrine that allows for the modification of gift restrictions, but in the past courts have tended to apply cy pres narrowly and privilege donor intent …

In The Beginning There Was None: Supreme Court Review Of State Criminal Prosecutions, Kevin C. Walsh

Law Faculty Publications

This Article challenges the unquestioned assumption of all contemporary scholars of federal jurisdiction that section 25 of the Judiciary Act of 1789 authorized Supreme Court appellate review of state criminal prosecutions. Section 25 has long been thought to be one of the most important provisions of the most important jurisdictional statute enacted by Congress. The Judiciary Act of 1789 gave concrete institutional shape to a federal judiciary only incompletely defined by Article III. And section 25 supplied a key piece of the structural relationship between the previously existing state court systems and the new federal court system that Congress constructed …

The Use Of Discussion At The Kindergarten Level To Advance Cognitive Abilities, Gayle J. Sears

Graduate Research Theses & Dissertations

The purpose of this mixed-methods study was to examine the use of discussion with preschool students for the development of language and cognitive abilities. The study focused on students who participated in 30 one-hour discussion lessons that were presented in an inner-city preschool classroom. The qualitative portion of the study involved an ethnographic examination of the discussion lessons, which were attended by a total of 22 students over a six-week period. Qualitative data were studied to determine how students responded to discussion and how student responses changed over time. The facilitation of discussion was analyzed, and the participation of individual …

The Relationship Of Perceived Social Support And The Big Five In Adolescents, Raymond L. Geosling

Graduate Research Theses & Dissertations

Social support is important for adolescents as it is related to outcomes such as anxiety, depression, and self-esteem. These associations are well established in the literature as known factors related to adolescents' perception of social support from parents, teachers, friends, and classmates. However, it is important for researchers to understand additional factors that are related to perceived social support. One factor that is relevant to all students is personality. This factor has been investigated with adolescents outside of the United States but has not been investigated with adolescents in the United States. The present study sought to investigate the relationship …

Principals' Perceptions Of The Impact Of Parent And Family Involvement Activities With Parents Of Latino Students, Rene D. Carranza

Graduate Research Theses & Dissertations

Latinos have a pattern of low academic achievement, starting in elementary school and persisting through high school and college. This pattern of achievement remains lower than that of any other group. In 2050, it is expected that Latinos will make up 30% of the U.S. workforce. This research looks at the role that parent involvement plays in academic achievement based on principals' perceptions. Perceptions are important because they influence behavior and decision making. The parent-involvement activities studied are based on the Epstein framework of six types. A survey was sent to 435 principals from the northwest suburbs of Chicago who …

Professional Learning Community And Non-Professional Learning Community Schools : A Quantitative Study Of Perceptions Of Teachers On Trust, Professionalism, And Change, Adam W. Zbrozek

Graduate Research Theses & Dissertations

The purpose of this study was to investigate the perceptions of teachers in Professional Learning Communities (PLC) and Non-PLC schools regarding Trust, Professionalism, and Change. The study included teaching staff of 10 Illinois elementary schools: five PLC schools and five non-PLC schools identified as demonstrating increasing levels of student achievement as measured by the annual state assessment (ISAT). Sampling was stratified in order to limit the population based on specific sets of characteristics. The study was limited to schools with demonstrated growth and success. Additionally, schools implementing PLCs that have been identified by Solution Tree were included in this study …

Smartphones Wandering At The Mall : A Case Study Investigating The Use Of Smartphones On English Oral Learning Skills In A Collaborative Mobile-Assisted Language Learning Environment, Anwer S. Al-Zahrani

Graduate Research Theses & Dissertations

The rapidly ever-changing pace of technology imposes the need for integrating new emerging technologies. Under the umbrellas of mobile learning and language learning, Mobile-Assisted Language Learning (MALL) finds its promising, new spot on the surface of emerging trends in education. In both the K-12 and higher education domains, future generations are more likely to own and be closely attached to mobile technologies more than ever.;As Mobile-Assisted Language Learning (MALL) facilitates language learning via mobile devices, many students strive to improve their English learning skills. Students usually struggle with listening and speaking because of the prompt nature of most conversations, unlike …

The Clerks Of The Four Horsemen (Part Ii, George Sutherland And Pierce Butler), Barry Cushman

Journal Articles

The names of Holmes clerks such as Tommy Corcoran and Francis Biddle, of Brandeis clerks such as Dean Acheson and Henry Friendly, and of Stone clerks such as Harold Leventhal and Herbert Wechsler ring down the pages of history. But how much do we really know about Carlyle Baer, Tench Marye, or Milton Musser? This article follows the interesting and often surprising lives and careers of the men who clerked for the Four Horsemen - Justices Van Devanter, McReynolds, Sutherland, and Butler. These biographical sketches confound easy stereotypes, and prove the adage that law, like politics, can make for strange …

Nanoparticle Behavior In Biological Gels And Biofluids: The Impact Of Interactions With Charged Biogels And The Formation Of Protein Coronas On Nanoparticles, Xiaolu Zhang

Theses and Dissertations--Chemistry

With the rapid growth of nanotechnology, situations where nanomaterials will interact with biological systems will unquestionably grow. Therefore, it is increasingly understood that interactions between nanomaterials and biological environments will play an essential role in nanomedicine. Biological polymer networks, including mucus and the extracellular matrix, serve as a filter for the exchange of molecules and nanoparticles. Such polymer networks are complex and heterogeneous hydrogel environments that regulate transport processes through finely tuned particle-network interactions. In chapters 3 and 4, we investigate the role of electrostatics on the basic mechanisms governing the diffusion of charged molecules inside model polymer networks by …

Designing Anthradithiophene Derivatives Suitable For Applications In Organic Electronics And Optoelectronics, Rawad Kamal Hallani

Theses and Dissertations--Chemistry

Anthradithiophene (ADT) derivatives have proven to be a front-runner in the world of small molecule semiconductors for organic electronics and optoelectronics. This is mainly due to the improved stability, easy tuning of chemical and physical properties, and impressive device performance that these molecules possess, especially in organic field effect transistors (OFET) and organic photovoltaics (OPV). The second chapter of this dissertation shows that reducing the amount of alkylsilylethynyl groups, used for functionalizing and solubilizing the ADT backbone, does alter the chemical, physical and crystallographic properties of ADTs. These changes offer the opportunity to study and observe different intermolecular interactions as …

Rock Hill Chamber Of Commerce Records - Accession 88, Rock Hill Chamber Of Commerce

Manuscript Collection

The Rock Hill Chamber of Commerce Records consist of correspondence, lists, brochures, pamphlets, program notes, magazine issues, newsletters, committee reports, financial data, and other records relating to the history and activities of the Chamber of Commerce. The collection contains records regarding sponsorship of Rock Hill’s “Come-See-Me” event and records of former Chamber Managers’ Vernon Grant and Clint Carpenter. Also contained are papers regarding Chamber accreditation, co-educational support for Winthrop University, area-wide racial integration, and recognition of Rock Hill as an All-America City.

Sushi And Sashimi: The Contaminated Bacteria And Helminthes, The Guidelines, Prasert Saichua, Amonrat Jumnainsong

Asian Medical Journal and Alternative Medicine

Sushi and sashimi are the fashionable dishes in Thailand over the last decade. The consumers believe that marine fish and other ingredients are the low calorie food and have various dietaries such as omega-3 polyunsaturated fatty acids, proteins and vitamins. However, several countries reported that the health risks of consuming sushi and sashimi are bacteria and helminthes infection. The contamination of these pathogens has been reported from many areas. In this paper, the illness from contaminated sushi and sashimi are reviewed. Additionally, the guidelines to control the quality in each step of sushi and sashimi preparing are noted. This paper …

Acoustic Emission Monitoring Of Multi-Phase Fluid Flow In Laser-Engineered Net Shaping Process (Lens), Justin Whiting

Graduate Research Theses & Dissertations

The Laser Engineered Net Shaping (LENS) Process uses an argon stream to direct metallic particulates at a molten pool created by a high-power Yb-fiber laser. The LENS process uses numerical control (NC) to manipulate the laser beam heat source in 3-dimensional space so parts can be built additively, layer-by-layer. The metal powder that is carried by the stream of argon gas creates a two-phase fluid, which can make measurement of mass flow rate difficult using conventional sensors. Maintaining a specified mass flow rate is essential in the quality control of this additive manufacturing process. An alternative device, an acoustic emission …

Where Is Our Revolution? : Workers In Ciudad Juarez And Parral-Santa Barbara During The 1930s, Andres Hijar

Graduate Research Theses & Dissertations

This dissertation explores the way workers on the border in Ciudad Juarez and in the mining district of Parral-Santa Barbara increased their power during the 1930s. Unionization, collective bargaining, labor tribunals, political alliances, and direct action gave workers control of crucial aspects of the production process for the first time in the nation's history. Furthermore, workers' efforts allowed them to extend their power beyond the workplace and into the community. In some instances, workers were radicalized, especially in the border city. To attenuate workers' rising power, political and economic elites intervened in labor conflicts in different ways depending on the …

Writing Against The Ethos Of Individualism : A Study In Contemporary Multiethnic American Fiction, Manahari Adhikari

Graduate Research Theses & Dissertations

Drawing from existential philosophy, neuroscience, and social psychology, in Writing Against the Ethos of Individualism: A Study in Contemporary Multiethnic American Fiction, I investigate the representation of the self in fictions by Bharati Mukherjee, Leslie Marmon Silko, Maxine Hong Kingston, Sandra Cisneros, and Toni Morrison. I argue that these writers imagine the lives of their fictional characters in terms of the phenomenology of existence and reveal how subjective experiences and personal relationships influence who these characters are and who they become. In imagining a self's authentic ontology in relation to others, multiethnic writers not only write against the dominant narratives …

Your Teacher Said What On Facebook : Application Of First Amendment Rights To Teacher Cyber Speech, Anthony M. Scarsella

Graduate Research Theses & Dissertations

There have been many recent instances of teachers being disciplined or terminated due to their activity on social networking sites. School administrators will likely be confronted with a growing number of reports of alleged inappropriate online teacher speech and required to make determinations regarding disciplinary action. This study researched the relevant history of judicial application of the U.S. Constitution's First Amendment free speech rights for public employees; investigated how the Supreme Court applied, modified and refined the judicial test outlined in Pickering v. Board of Educ. in public employee free speech cases and; examined how the United States federal Circuit …

Can Consumers Perceive A Difference In Quality When Comparing Whole-Grain Gluten-Free Baked Goods To Refined Gluten-Free Baked Goods At Varying Flour Levels, Jenna R. Carlson

Masters Theses

The prevalence of celiac disease and gluten intolerances has increased drastically in the last few decades, accounting for 1 in 100 individuals, or about 1% of Americans (Mager, Qiao, & Turner, 2012). The only treatment for celiac disease or any other gluten intolerance is the gluten-free diet. The gluten-free diet can lack many essential nutrients. The purpose of this research was to identify if consumers could perceive a difference in quality when comparing whole-grain gluten-free baked goods to refined gluten-free baked goods at varying flour levels of 20%, 50%, and 100%.

The researcher-developed Carlson Acceptability of Gluten-Free Baked Goods Survey …

A Historical Analysis On The Status Of Unilateral Private Placements In Special Education, Jeremy Lambe

Graduate Research Theses & Dissertations

With the passage of the Education for All Handicapped Children Act (EAHCA) in 1975, parents were provided the right to a hearing if they did not agree with the special educational services being provided to their child. However, it was not until the IDEA 1997 amendments that tuition reimbursement was specifically offered when a school district failed to provide a free and appropriate public education (FAPE) to a child with a disability. In current times, when parents disagree about the services provided to their child, they often do not wait for the due process procedure to resolve the issue. Instead, …

A Legal Analysis Of School Vouchers And The Social Justice Impact, Michael Patrick Ryan

Graduate Research Theses & Dissertations

While our nation's best students can generally be found in predominately white, suburban, and middle to upper-middle class school districts, our weakest students can generally be found in predominately inner-city school districts with high minority populations. To address the disparities between schools a variety of reforms, initiatives, and programs have been created and implemented -- with seemingly little if any long-lasting positive effects. It is this researcher's contention that the one reform movement that is different from the other measures is school choice. It is different because it is the only reform measure that leaves the decision on what is …

Analysis Of Joints With V Band And T Bolts, Badrinath Kodarapu

Graduate Research Theses & Dissertations

T bolts with V bands are used to hold two sections of pipe together with each section of pipe having a flared flange at the ends. Though they are quite popular in various industries including heavy duty diesel engines, analysis involving these joints is not available. This thesis would involve static and dynamic behavior of the joints. Behavior of these joints in comparison with bolted joints are also provided.

Applying Frances Fowler's Model To Analyze The History Of Compulsory Attendance Laws In The United States, Deborah Dyer Osborne

Graduate Research Theses & Dissertations

The notion of compelling formal education has been in existence since the 1600's. Subtle differences can be extrapolated from the compulsory school attendance statutes enacted during the past four centuries; however, the core requirements have remained the same. Despite the fact the United States Supreme Court has ruled education is not a fundamental right. Every state has laws mandating school attendance for minor children. For centuries, judicial efforts have wrestled with crafting effective interventions and punishments for students and parents failing to follow these laws. Sadly, truancy continues to be a plague in 21st century education. There continues to be …

Autistic Texts And Textual Accounts Of Autism : The Interdependence Of 20th - And 21st - Century Science And Literature Through The Rhetorical Phenomenon Of Autism, John Joseph Marinan Iv

Graduate Research Theses & Dissertations

In this dissertation, I illustrated how throughout the 20th and 21st centuries the science community has officially identified and objectified autism: first, by connecting it with psychoanalysis through schizophrenia; second, by creating other categories such as infantile autism and Asperger syndrome that focused on psychological and medical factors; third, by pointing to Theory of Mind applications that emphasized brain chemistry; and finally, by tracing recent theories of morphology relating to mirror neurons and rapid early brain growth. Despite attempts to define autism as a diagnostic term imbued with empirical qualities, the process of writing about it also created autism as …

"I'M Sorry For The Mistakes I'M About To Make" : Interaction, Social Status And Emotion In The Indonesian Efl Classroom, Francesca Pase

Graduate Research Theses & Dissertations

This paper explores the relationship between language, culture, and emotion in the Indonesian English as a foreign language (EFL) classroom. It does this by focusing on the Indonesian concept of malu, an emotional response often translated as "shame." Malu is a complex emotional construct that determines appropriate behavior and is activated situationally, often as a way of indicating respect. By investigating how students and teachers navigate the application of the communicative approach of language acquisition in the presence of malu, we are able to gain insights into the world of the Indonesian English learner. This study was conducted in the …

A Case Study Of An Effective Teacher In Relation To Responsibility-Based Practices, Janel Grzetich

Graduate Research Theses & Dissertations

This dissertation examines the practices of a middle school teacher who was known to be effective in relation to a responsibility-based teacher evaluation system. Specifically, it presents an analysis of teaching behaviors present during 12 lessons videotaped throughout the course of a school year. The Tool for Assessing Responsibility-Based Education (TARE) was used to analyze frequencies of responsibility-based behaviors associated with specific categories. These categories were Modeling Respect, Setting Expectations, Opportunities for Success, Fostering Social Interaction, Assigning Tasks, Leadership, Giving Choices and Voices, Role in Assessment, and Transfer. Additionally, teacher participants were shown segments of the exemplar's teaching and provided …

Development Of A Rhythmic Achievement Test For Elementary General Music Students, Jeanette Susan Brooks

Graduate Research Theses & Dissertations

With today's heightened focus on accountability, many states are moving to a system where evidence of student achievement is a component of teacher evaluation. Music education does not have a tradition of measuring individual students in a standardized manner. Gordon (2012) points out, "a serious problem in music education is many teachers rarely measure students' achievement, yet they continuously evaluate it often using subjective results to indirectly appraise effectiveness of their own teaching"(p. 323). Thus, it is critical for music educators to develop high-quality assessments that accurately measure student ability. This dissertation centers on the development of rhythmic achievement test …

Elementary And Middle School Second Language Learning Program Models And Pronunciation Achievement, Monica Elaine Ploger

Graduate Research Theses & Dissertations

There is increased interest in adding second language programming before high school, including Foreign Language in the Elementary Schools (FLES) and dual language (DL) programs. Research shows many benefits of learning a second language in elementary and middle school programs, such as allowing more time to develop fluency and fostering positive attitudes toward cultural diversity prior to the crucial age of 10 (Curtain & Pesola, 1994). However, no one has compared these program types based upon phonology, which is easier to learn before puberty. While prior literature provides studies of the target Spanish sounds, including vowels and the trilled /r/, …

Empire Of The Scene : Film Adaptations Of The Novels Of J. G. Ballard, Scott R. Stalcup

Graduate Research Theses & Dissertations

This study examines primarily the adaptations of J. G. Ballard's novels Empire of the Sun and Crash, directed respectively by Steven Spielberg and David Cronenberg. An overview of the production histories, the contrasts between the films and their source texts, and the reception by audiences, as well as Ballard himself are addressed. In addition, the study examines lesser-known/less available adaptations of Ballard's writing, specifically Sam Scoggins' take on The Unlimited Dream Company, Solvieg Nordlund's adaptations of "The Low-Flying Aircraft" and "Thirteen to Centaurus," Jonathan Weiss' The Atrocity Exhibition, as well as looking ahead to the Ben Wheatley-helmed High-Rise currently in …

Can Motivation Facilitate L1 English-L2 Spanish Learners' Acquisition Of L2 Phonology?, Marion Rebecca Gibney-Desmaison

Graduate Research Theses & Dissertations

Phonology is one of the most difficult aspects of a second language (L2) for learners to fully acquire, yet pronunciation of sounds that are similar across languages is rarely addressed in L2 Spanish classes. If two sounds are very similar between two languages, they are actually more difficult for learners to differentiate. How does learner motivation affect the acquisition of L2 sounds that are similar to the first language (L1)?;The present study investigates the connection between student motivation toward learning a foreign language and student L2 accent production. Ten L1 English-L2 Spanish learners from two different (fourth- and fifth-semester) Spanish …

Centered On Writing : The Relationship Among Writing Centers, Writing Programs, And Training Methodology, Anne Kathleen Marquette

Graduate Research Theses & Dissertations

This thesis is focused on writing center training methods and the ideologies transmitted through training to new writing tutors. It examines the effect of the working relationship among writing centers and the other writing programs on their campuses on training. This examination found that while the closeness of these working relationships did not affect training methodology, it was related to the ideologies emphasized during training. Specifically, writing centers with close working relationships with other campus writing programs emphasized non-directive tutoring in training less often than writing centers with distant or no working relationships. Furthermore, the importance of tutors' interpersonal skills …