Digital Commons Network^™

Beyond Frustration: Section 162(F) And The Deductibility Of Fines, Penaties, And Settlement Payments, Abraham N.M. Shashy Jr., Sara A. Silverstein, Ariana F. Wallizada

Florida Tax Review

The Merriam-Webster online dictionary defines frustration as a deep chronic sense or state of insecurity and dissatisfaction arising from unresolved problems or unfulfilled needs. It lists as synonyms: aggravation, bother, botheration, bugbear, exasperation, annoyance, hairshirt, hassle, headache, inconvenience, irk, irritant, nuisance, peeve, pest, rub, ruffle, thorn, trial, and vexation. It has been said that to conquer frustration one must remain intensely focused on the outcome, not the obstacles.

This Article owes its existence to frustration on two counts. The substantive topic is section 162(f). It was Congress's response in 1969 to certain deductions claimed by taxpayers that were thought to …

The Impact Of Sars-Cov-2 On The Consolidated Meatpacking System In The United States, Judith R. Solomon

Anthós

The Sars-Cov-2 virus has had a particularly intense impact on the meatpacking industry in the United States. In this paper I provide a brief introduction to the social, economic, and political realities that lead to mass deaths of meatpacking workers from COVID, and the impact of a consolidated meatpacking system on disease mitigation. These workers are considered expendable due to a lack of power.

Spacs, Forward-Looking Statements, And Rule 419: Is Sec Rulemaking Needed?, Nicholas Vota

St. John's Law Review

(Excerpt)

On October 8, 2020, FirstMark Horizon Acquisition Corp. (“FirstMark” or “Company”) closed an initial public offering (“IPO”) of 41,400,000 units. Each unit was priced at $10.00 and “consist[ed] of one share of Class A common stock of the Company . . . and one-third of one redeemable warrant of the Company.” Each whole warrant provided its holder with the right to purchase “one share of Class A [c]ommon [s]tock for $11.50 per share.” FirstMark generated $414,000,000 in connection with the IPO. These funds were then placed in a trust account and maintained by a trustee.

In a filing submitted …

Generalizing Graph Neural Networks Across Graphs, Time, And Tasks, Zhihao Wen

Dissertations and Theses Collection (Open Access)

Graph-structured data are ubiquitous across numerous real-world contexts, encompassing social networks, commercial graphs, bibliographic networks, and biological systems. Delving into the analysis of these graphs can yield significant understanding pertaining to their corresponding application fields.Graph representation learning offers a potent solution to graph analytics challenges by transforming a graph into a low-dimensional space while preserving its information to the greatest extent possible. This conversion into low-dimensional vectors enables the efficient computation of subsequent graph algorithms. The majority of prior research has concentrated on deriving node representations from a single, static graph. However, numerous real-world situations demand rapid generation of representations …

Balancing Privacy And Accuracy In Iot Using Domain-Specific Features For Time Series Classification, Pranshul Lakhanpal

Master's Theses

ε-Differential Privacy (DP) has been popularly used for anonymizing data to protect sensitive information and for machine learning (ML) tasks. However, there is a trade-off in balancing privacy and achieving ML accuracy since ε-DP reduces the model’s accuracy for classification tasks. Moreover, not many studies have applied DP to time series from sensors and Internet-of-Things (IoT) devices. In this work, we try to achieve the accuracy of ML models trained with ε-DP data to be as close to the ML models trained with non-anonymized data for two different physiological time series. We propose to transform time series into domain-specific 2D …

Ai Approaches To Understand Human Deceptions, Perceptions, And Perspectives In Social Media, Chih-Yuan Li

Dissertations

Social media platforms have created virtual space for sharing user generated information, connecting, and interacting among users. However, there are research and societal challenges: 1) The users are generating and sharing the disinformation 2) It is difficult to understand citizens' perceptions or opinions expressed on wide variety of topics; and 3) There are overloaded information and echo chamber problems without overall understanding of the different perspectives taken by different people or groups.

This dissertation addresses these three research challenges with advanced AI and Machine Learning approaches. To address the fake news, as deceptions on the facts, this dissertation presents Machine …

Watchdogs That Failed To Bark: Standards Of Tax Review After Enron, Harold S. Peckron

Florida Tax Review

Enron Corporation, which was the seventh-largest U.S. corporation prior to its collapse, will long be a case study on various corporate governance and ethical failures. But the most frightening aspect of Enron is that it was never designed or intended to be a massive fraudulent scheme from its inception, unlike many substantial financial frauds.

It began by simply trading energy futures and eventually expanded to trading futures in commodities well beyond the company’s expertise. To continue its positive financial performance, the company required its advisors to develop “blowback” strategies ensuring continued stock price appreciation.

These so-called “strategies” were largely concerned …

The Ethical Implications Of The Multi-Level Marketing Industry, Lauren Longworth

Marketing Undergraduate Honors Theses

The first multi-level marketing (MLM) businesses were created in the early 20th century and have seen a substantial increase in popularity during the COVID-19 pandemic due to their work-from-anywhere nature. Multi-level marketing is “the practice of distributing, selling or supplying products or services through various levels of independent agents” (Koehn, 2001, p. 153). As working from home became the norm in the past few years, MLM businesses promised financial freedom, a steady income, and opportunities for growth, all by working on the Internet. What was often less transparent is the likelihood of these independent agents making a profit. Distributors have …

Exploring Antecedents Of Generation Y And Z Customers’ Intention To Adopt Cryptocurrency Payments In The Context Of Hotels: A Sequential Mixed-Methods Study, Jehun Moon

UNLV Theses, Dissertations, Professional Papers, and Capstones

Cryptocurrency payments (CPs) are an innovative technology that can disrupt the hospitality industry. However, studies on the antecedents of CP adoption are scarce. To bridge this gap, this study targeted Gen Y and Z, the potential primary user groups, to explore the determinants of intention to adopt CPs. A mixed-methods approach was used to capture the depth and breadth of understanding of factors that impact Gen Y and Z customers’ CP adoption intentions. Study 1, a qualitative study, was utilized to acquire contextualized components. In parallel, Study 2 used a quantitative approach to validate the proposed research model, which combined …

Accounting And Financial Statements Auto Analysis System, Zhen Jia

Electronic Theses, Projects, and Dissertations

This project was motivated by the need to revolutionize the generation of financial statements and financial analysis process thus speeding up business decision making. The research questions were: 1) How can machine learning increase the speed of financial statement preparation and automate financial statements analysis? 2) How can businesses balance the benefits of automating financial analysis with potential concerns around privacy, data security, and bias? 3) Can the Java J2EE framework provide a reliable running environment for machine learning?

The findings were: 1) Machine learning can significantly increase the accuracy and speed of financial analysis. Using machine learning algorithms, financial …

Insurgent Intentions: Are Retail Investors On Social Media Subject To Federal Market Manipulation Laws?, Jack Ruello

Louisiana Law Review

No abstract provided.

Uc-388 Quantum Computing In Cybersecurity Related Data Analysis : A Comparative Analysis Of Classical And Quantum Machine Learning Models On Various Security Threats, Ryan Lowhorn, Zac Cardwell

C-Day Computing Showcase

Financial fraud has become an increasingly prevalent and sophisticated issue in the modern world, causing significant losses for individuals, businesses, and economies alike. The exponential growth of digital transactions has only accelerated the need for effective and efficient fraud detection systems to safeguard these financial ecosystems. Traditional machine learning techniques, such as Neural Networks (NNs), K-Nearest Neighbors (KNN), and Support Vector Machines (SVM), have played a crucial role in mitigating the impact of fraud by employing advanced algorithms to identify and prevent fraudulent transactions. With the recent advent of quantum computing and its potential to revolutionize the field of machine …

Clerical-Collar Crime: How Church Members Deal When Church Leaders Steal Church Property, Preslie B. Grumbles

Texas A&M Journal of Property Law

Christian churches will lose an estimated $59 billion worldwide to embezzlement in 2022. Embezzlement and other white-collar crimes are property theft crimes characterized by the violation of another’s trust. This Comment names white-collar crimes committed exclusively by church leaders or officials “clerical-collar crimes.” Distinguishing clerical-collar crime from white-collar crime gives weight to and promotes future consideration of the unique problems that arise when church leaders and officials commit clerical-collar crime.
Although clerical-collar crime is subject to civil and criminal liability, this Comment focuses solely on victims’ experiences in bringing civil claims against perpetrators of clerical-collar crime in Texas and leaves …

Bolsonaro: Extradition And The Limits Of The Political Exception Doctrine, Allison Herstic

Cardozo International & Comparative Law Review (CICLR) Blog

Former Brazilian President Jair Bolsonaro’s recent move to Florida represents a potential clash between the immunity afforded to former political leaders and the notion of extradition – a treaty-based obligation to return individuals charged with offenses to their home country.

This post was originally published on the Cardozo International & Comparative Law Review on April 3, 2023. The original post can be accessed via the Archived Link button above.

The Charter School Network (Almost) No One Wants, Joni Hersch, Colton Cronin

Vanderbilt Law School Faculty Publications

Publicly funded, independently operated charter schools entered the public sector three decades ago with the promise of innovating public education to better serve students in underperforming schools. Despite limited evidence of improved educational outcomes, charter schools are now an established part of the education system, with around 7,800 charter schools serving more than seven percent of public, school students.

Although charter schools have long been associated with the controversial school choice movement, a recent entrant into the charter school arena has created new and urgent concerns. Hillsdale College, through its affiliate Barney Charter School Initiative, has been making escalating inroads …

The Charter School Network (Almost) No One Wants: Mobilizing Regulation And Litigation To Serve The Public Interest, Joni Hersch, Colton Cronin

Cardozo Law Review

Publicly funded, independently operated charter schools entered the public sector three decades ago with the promise of innovating public education to better serve students in underperforming schools. Despite limited evidence of improved educational outcomes, charter schools are now an established part of the education system, with around 7,800 charter schools serving more than seven percent of public, school students.

Although charter schools have long been associated with the controversial school choice movement, a recent entrant into the charter school arena has created new and urgent concerns. Hillsdale College, through its affiliate Barney Charter School Initiative, has been making escalating inroads …

Artificial Intelligence-Altered Videos (Deepfakes), Image-Based Sexual Abuse, And Data Privacy Concerns, Chidera Okolie

Journal of International Women's Studies

Artificial Intelligence (AI) is a phenomenon that has become embedded in human life, and this symbiotic relationship between technology and humanity is here to stay. One such use of AI is deepfakes. The use of AI for deepfakes is arguably one of the most controversial topics because it raises ethical issues. Deepfakes are images or recordings that have been convincingly altered and manipulated to misrepresent someone as doing or saying something that they did not actually do or say. These manipulations thrive in the political arena and recently in the pornography industry, in which women’s faces are masked onto other …

Conflicts Of Interest At An Organization’S Highest Authority: How The District Of Columbia’S Rules Of Professional Conduct Can Fail To Protect Private Organizations, Christopher Deubert

Catholic University Law Review

This Article examines how the District of Columbia’s incomplete incorporation of the Model Rules of Professional Conduct into its own Rules of Professional Conduct has created a scenario in which wrongdoing inside a private organization can flourish. In 2002, following the Enron scandal, the American Bar Association (ABA) revisited and revised its Model Rules of Professional Conduct. The ABA nevertheless took a conservative route, rejecting rules long proposed by experts which would have permitted attorneys aware of corporate crimes, fraud, and other wrongdoing to report their concerns to individuals or entities outside the organization’s reporting structure. Additional scandals unfolded contemporaneous …

A Modern Defense Of Simple Rules For A Complex World, Richard A. Epstein

Texas A&M Law Review

My 1995 book Simple Rules for a Complex World articulated a general proposition that, in most situations, simple legal rules perform better in two key dimensions: (1) they are simpler to interpret and enforce, and (2) they generate efficient incentives on the parties to whom they apply. I then applied that view to matters of general legal theory, to matters of environmental law, and to disputes over labor. These principles apply to all forms of legal regulation, but in this Article, I shall limit my analysis to the five articles in this Collection. These are by Richard Revesz on global …

Fugitive Pull: Applying The Fugitive Disentitlement Doctrine To Foreign Defendants, Zachary Z. Schroeder

Washington Law Review

Defendants force courts to decide whether to use judicial time and resources to hear a case when they either flee or refuse to submit to jurisdiction. Judges in the United States possess an exceptional discretionary power to deny access to the courts in these circumstances through the fugitive disentitlement doctrine. The fugitive disentitlement doctrine developed as federal common law and permits courts to exercise discretion in declining to hear appeals or motions from defendants classified as fugitives from justice.

Historically, the fugitive disentitlement doctrine was intended to prevent courts from wasting resources adjudicating cases when a defendant has fled and …

The Role Of Whisteblowers In The Recovery Of Covid-19 Relief Funds And The Need To Expand The Fca's Qui Tam Provision, Ashley Miskovsky

Hofstra Labor & Employment Law Journal

No abstract provided.

Digital Asset Regulation: Peering Into The Past, Peering Into The Future, Kevin Werbach

William & Mary Law Review

Blockchain is often compared to the internet as a disruptive technology that will realign economic structures across the world. This analogy extends to law and regulation. Similar to internet-based services, digital assets raise a host of challenges for policymakers. They also pose general questions regarding the desirability and practicality of regulating decentralized systems. Such debates play out against a backdrop of concerns that regulatory action will chill innovation or push market activity to more tolerant jurisdictions. The story of internet policy in the late 1990s and early 2000s therefore provides important lessons for policymakers today when confronting digital assets. Two …

Family Wealth Advisory Services In China – What Kind Of Advisors Can Be More Competent And Successful?, Yang Shen

Dissertations and Theses Collection (Open Access)

High net worth wealth owners generally need various advisory services to meet their wealth management needs, such as investment / global asset allocation, intergenerational succession planning, personal and family tax planning, next-generation education, health management, immigration arrangement for family members, etc.

At the current stage, this paper tries to answer below central research questions for Chinese wealth advisors:

1. From the Perspective of high-net-worth individuals (HNWI) in China, what characteristics should their wealth advisors bear to be considered competent?
2. Which key competency factors are mostly important in making the wealth advisor successful (reflected through performance rating of wealth advisors)?

The research …

Peer Effects In Equity Research, Kenny Phua, Mandy Tham, Chi Shen Wei

Research Collection Lee Kong Chian School Of Business

We study the importance of peer effects among sell-side analysts who work at the same brokerage house, but cover different firms. By mapping the information network within each brokerage, we identify analysts who occupy central positions in their network. Central analysts incorporate more information from their coworkers and produce better research. Using shocks to network structures around brokerage mergers, we identify the influence of peer effects and the importance of industry expertise on analysts’ performance. A portfolio strategy that exploits the forecast revisions of central analysts earns up to 24% per annum.

Standing Up To Hackers: Article Iii Standing For Victims Of Data Breaches, Kendall Coffey

University of Miami Law Review

Despite the increasing amount of data breaches, there is no liability for parties who do not adequately protect victim’s information. In federal court, plaintiffs must show that their injury was concrete, particularized, and imminent. But, when plaintiffs’ information has been stolen, but not yet criminally used, they may be unable to establish a right to relief. Victims face challenges when seeking damage for this future harm, because despite their destroyed privacy, they may not have evidence of a perpetrator’s actual misuse of purloined data. This Article analyzes multiple court decisions, generally in the setting of class-actions, and discusses outcomes of …

The Blacklist: Post-Employment Retaliation Under Thefalse Claims Act, Katelyn Deibler

Ohio Northern University Law Review

No abstract provided.

Huawei, Internet Governance, And Ieepa Reform, David W. Opderbeck

Ohio Northern University Law Review

No abstract provided.

Privacy And Security Information Awareness And Disclosure Of Private Information By Users Of Online Social Media In The Ibadan Metropolis, Nigeria, Funmilola Olubunmi Omotayo, Joy Oluwabukola Olayiwola

The African Journal of Information Systems

The purpose of this paper is to investigate information privacy and security awareness among online social media (OSM) users in the Ibadan metropolis, Nigeria. Building upon the social exchange theory, some factors that could influence the disclosure of private information on social media were identified. Findings from the analysis of data of 255 respondents revealed that most were aware of information privacy and security measures available on OSM, and the risks associated with the disclosure of private information on OSM. Privacy and security awareness, the perception of benefits associated with the use of OSM, the perception of risks associated with …

Scalable And Globally Optimal Generalized L1 K-Center Clustering Via Constraint Generation In Mixed Integer Linear Programming, Aravinth Chembu, Scott Sanner, Hassan Khurram, Akshat Kumar

Research Collection School Of Computing and Information Systems

The k-center clustering algorithm, introduced over 35 years ago, is known to be robust to class imbalance prevalent in many clustering problems and has various applications such as data summarization, document clustering, and facility location determination. Unfortunately, existing k-center algorithms provide highly suboptimal solutions that can limit their practical application, reproducibility, and clustering quality. In this paper, we provide a novel scalable and globally optimal solution to a popular variant of the k-center problem known as generalized L1 k-center clustering that uses L1 distance and allows the selection of arbitrary vectors as cluster centers. We show that this clustering objective …

Following Their Predecessors' Journey? A Review Of Emne Studies And Avenues For Interdisciplinary Inquiry, Peter J. Buckley, Lin Cui, Liang Chen, Yi Li, Yoona Choi

Research Collection Lee Kong Chian School Of Business

In this review article we take stock of international business (IB) research on emerging economy multinational enterprises (EMNEs) over the past three decades. Our review covers 690 articles published in 64 high-impact peer-reviewed journals between 1990 and 2021 (inclusive). We first present bibliometric findings on some key patterns of this vast body of scholarly work. We then conduct content analysis to critically assess this literature and provide a multilevel synthesis of the existing knowledge base. To do so we propose a theoretical framework that highlights three dimensions - micro-foundations, organizational characteristics, and institutional environment - by which the distinction between …