Digital Commons Network^™

The Internal Revenue Code's Section 351 Implied Deferred Tax Liability Problem, Stanley Veliotis

Pace Law Review

Most people take for granted that the fair market value of property exchanged for other property is of equal value. However, in the case of transfers of appreciated property to a corporation in a transaction qualifying for non-recognition under Section 351, the creation of a second unrealized gain in the hands of the transferee corporation—and thus a newly created implied deferred tax liability on such gain when later realized—reduces the value of the stock issued to the shareholder. Despite this, in Section 351 settings academics, textbook and casebook writers, the Treasury, and the courts take a standard approach of equating …

Why Not More Seats? Increasing The House Of Representative's Size Using The Least Populous State Solution, Jennifer Kindred Mitchell

Pace Law Review

Representative democracy is for the people, by the people. But what happens when the connection between the people’s representative and their constituents erodes over time due to increased population and district size? The United States House of Representatives’ membership has been capped at 435 for almost 100 years leading to an increase in the average district size from 280,875 in 1930 to 761,169 in 2020. House membership and constituents represented by each member is out of balance, causing a decrease in representative democracy, large over and underrepresented district disparities, and feelings of disenfranchisement by citizens. Therefore, this paper premises that …

" A Beautiful Maiden Shot My Heart" By Antar Bin Shadad:, Yasser K. R. Aman

Comparative Woman

This is a translation of an Arabic poem from Pre-Islamic poetry written by Antara Bin Shadad. This poem is an example of appropriation in literary translation. When the meaning is not only cultural but when it is ambience- bound as well, appropriation is difficult but not impossible to achieve. " رمتِ الفؤادَ مليحة عذراءُ" " A Beautiful Maiden Shot My Heart" is an example of a hard choice whether to translate a poem into classical or modern poetry. However, the best I have done was to appropriate between both choices. Images are almost kept the same, but the classical style, …

Willie D. Hutley

African American Funeral Programs

Willie_D_Hutley.pdf - Funeral program for Willie D. Hutley

Mr. Willie Walt Hunter

African American Funeral Programs

Mr_Willie_Walt_Hunter.pdf - Funeral program for Mr. Willie Walt Hunter

Mr. Morgan Holmes

African American Funeral Programs

Mr_Morgan_Holmes - Death notice for Mr. Morgan Holmes

Jaunita Hunter

African American Funeral Programs

Jaunita_Hunter.pdf - Death notice for Jaunita Hunter

Mr. Clifford Jackson

African American Funeral Programs

Mr_Clifford_Jackson_Jr.pdf - Funeral program for Mrs. Clifford Jackson

Culture & Society In Ecuador And The United States, Kai Szostak

2024-2025 Field Notes

While still in the midst of their study abroad experiences, students at Linfield University write reflective essays. Their essays address issues of cultural similarity and difference, compare lifestyles, mores, norms, and habits between their host countries and home, and examine changes in perceptions about their host countries and the United States. In this essay, Kai Szostak describes observations during their study abroad program at the Galapagos Academic Institute for the Arts and Sciences in Ecuador.

Blazing Trails, Erik Johnson

Natural Science Faculty

Comets have always captivated people. Some cultures saw the appearance of comets as omens and some have hypothesized that a comet served as the Star of Bethlehem from the Nativity story.

Body, Mind, And Archives: A Critical Questioning Of “Places For Knowledge” In David Treuer’S The Translation Of Dr. Apelles, Lisa Brau-Weglinski

Comparative Woman

Western conceptualizations of time and space are common topics to be queried within the field of Indigenous literary study. However, while the focus has been laid on temporal and spatial literary conventions, too little attention has been drawn to the conceptualization and norms around an identity forming element: knowledge. This paper is particularly suspicious of Western conceptualizations of “places for knowledge,” as this has very real consequences for how we understand and treat ourselves and others. As such, my work highlights that “places for knowledge” can cloud and limit our perception of reality, which, concerning the project of decolonization …

Mapping Gender And Territory: The Continent Allegories On European World Maps From The Late Middle Ages To The Renaissance Until The Early Enlightenment, Katharina Eva Oehmichen

Comparative Woman

The four-part set of female continent allegories, which originated in the early Renaissance, was born out of a European need for a new vehicle of thought that served the functions of representing imperial expansion and the superiority of Western science and civilization, while gratifying the curiosity of the readers about newly discovered lands at the same time. The shift from the Christian symbolic tradition of the representation of the continents on world maps mirrored the shift in Western perception and knowledge of the world and Europe’s position in it. Apart from geo-political and imperial agendas that might have favored a …

How Seamlessly...., Pulkita Anand

Comparative Woman

No abstract provided.

Living Losses, Courtney A. Brown Phd

Comparative Woman

Contextually, I am from a line of strong black women. I am from a community of strivers and survivors who’ve accomplished great things through the blanket of patriarchy and civil injustices. I stand on the shoulders of many who took literal and figurative hits so that I could have opportunities they only dreamed of. I have followed in this legacy shattering glass ceilings into unrecognizable pieces for those who will come next.

However, breaking through has not come without cuts, bruises, scrapes and wounds. The celebration of smashing stereotypes should at least be balanced with the acknowledgement of the formidable …

Queering Critical Consciousness: Measurement And Implications Of Critical Consciousness Among Sexual And Gender Minority Youth, Esther Burson, Erin B. Godfrey, Deanna A. Ibrahim, Hirokazu Yoshikawa, Jerel P. Calzo, V. Paul Poteat

Psychology: Faculty Publications

We consider critical consciousness among sexual and gender minority (SGM) youth. Factor analytic and measurement invariance analyses were conducted across straight Black and Latinx youth (N = 254), SGM Black and Latinx youth (N = 111), and SGM white youth (N = 458). Factors of critical reflection and political efficacy emerged in all groups. Configural and partial metric invariance, but not scalar or residual invariance, were established. Correlations between political efficacy and wellbeing and grades replicated across groups. Critical reflection was associated with grades only for white youth, while critical action was associated with grades only for non-white youth. Implications …

The Impact Of Employee Voice On Creative Performance: An Analytical Research In The Number Of Industrial Companies, Wafaa Juda Badi, Ghani Dahham Al Zubaidi

Journal of Economics and Administrative Sciences

Today, business organizations , seek to build creative capabilities by adopting advanced management concepts and methods such as employee voice to enable them facing potential challenges. This research investigates the impact of employee's voice on creative performance in a number of industrial companies in Baghdad City. The research's problem is started by the issues with weakness in corporate consciousness and the knowledge of employee voice that restrict firms from developing and innovating, and ignoring those voices except concerning the interest of companies. The main question of the research's problem is (What is the level of impact for employee voice on …

Analysing And Measuring The Impact Of The Structural Imbalance Of The Saudi Economy On The Balance Of The General Budget For The Period 1990-2021, Zozan Mohammed Salih, Rijwan J. Abdulrahman Aldosakee, Sarkar Ismael Haso

Journal of Economics and Administrative Sciences

The research aims to show the impact of structural imbalances in the main sectors in the Kingdom of Saudi Arabia by testing the relationship in the short and long term between the variables of the structure of the main sectors of industry, agriculture, and mining, in addition to the price of oil as independent variables, and between the public budget expressed by 1990-2021. The results have resulted in a long-term relationship between the main sectors and the oil price and between the deficit and the surplus of the general budget with a negative correction factor of (-0.77) in order to …

Comparison Between Estimates Of Beta Regression Model Using Mse, Melad Dheyaa Ismaiel, Ahmed Dheyab Ahmed

Journal of Economics and Administrative Sciences

The multiple linear regression analysis shows the effects of explanatory variables on the dependent variable. Its function is to represent data to understand the shape and nature of the relationship between explanatory variables and the response variable. One of the main problems faced by linear regression is the nature of the data, as sometimes it does not follow a normal distribution. This has led to the emergence of different types of linear regression models such as the beta regression model, where the data of the dependent variable is less than one and confined within the period (0,1), and the data …

Self-Doubt: Impostor Phenomenon And The Doctoral Seeking School-Based Leader, Rose Apollon-Simon

USF Tampa Graduate Theses and Dissertations

This qualitative narrative inquiry explores the experiences of school-based administrators in K-12 public school settings within the state of Florida who navigate the challenges of Impostor Phenomenon while concurrently pursuing a doctoral degree. The research draws on the personal stories of four participants—three women and one man—who are currently or previously employed as principals or assistant principals. The study focused on how participants manage the psychological tensions coming from their experiences with Impostor Phenomenon or the persistent self-doubt and the fear of being exposed as a fraud. While most Impostor Phenomenon research has concentrated on fields like business, medicine, and …

On The Role Of Prediction In Streaming Hierarchical Learning, Ramy Mounir

USF Tampa Graduate Theses and Dissertations

In today's world, AI systems need to make sense of large amounts of data as it unfolds in real-time, whether it's a video from surveillance and monitoring cameras, streams of egocentric footage, or sequences in other domains such as text or audio. The ability to break these continuous data streams into meaningful events, discover nested structures, and predict what might happen next at different levels of abstraction is crucial for applications ranging from passive surveillance systems to sensory-motor autonomous learning. However, most existing models rely heavily on large, annotated datasets with fixed data distributions and offline epoch-based training, which makes …

Integrating Ecophysiology And Omics To Unlock Crop Response To Drought And Herbivory Stress, Insha Shafi, Manish Gautam, Rupesh Kariyat

Entomology Faculty Publications and Presentations

Introduction: Plants are constantly exposed to a diverse spectrum of environmental stressors that typically occur concurrently as multifactorial challenges, both spatially and temporally (Joshi et al., 2024). These stressors include abiotic stresses, such as drought, flooding, salinity, nutrient deficiencies, metal toxicity and extreme temperatures, as well as biotic pressures such as herbivory, pathogen attacks, and inter and intraspecific competition (Porter et al., 2020; González Guzmán et al., 2022). Drought and herbivory are arguably among the most critical factors that limit crop productivity in agricultural settings (Gautam et al., 2024), making it imperative to understand plant responses to their combined effects. …

24 Conference Program - Mixed Conducting And Nonstoichiometric Compounds Viii, William Chueh, Kuan-Zong Fung, Hitoshi Takamura

Mixed Conducting and Nonstoichiometric Compounds VII

No abstract provided.

Review Of Human Behavior And The Social Environment Ii, Minzhi Ye

Open Educational Resources - Reviews

No abstract provided.

Imitasd: Imitation Assessment Model For Children With Autism Based On Human Pose Estimation, Hany Said, Khaled Mahar, Shaymaa E. Sorour, Ahmed Elsheshai, Ramy Shaaban, Mohamed Hesham, Mustafa Khadr, Youssef A. Mehanna, Ammar Basha, Fahima A. Maghraby

Instructional Technology and Learning Sciences Faculty Publications

Autism is a challenging brain disorder affecting children at global and national scales. Applied behavior analysis is commonly conducted as an efficient medical therapy for children. This paper focused on one paradigm of applied behavior analysis, imitation, where children mimic certain lessons to enhance children’s social behavior and play skills. This paper introduces IMITASD, a practical monitoring assessment model designed to evaluate autistic children’s behaviors efficiently. The proposed model provides an efficient solution for clinics and homes equipped with mid-specification computers attached to webcams. IMITASD automates the scoring of autistic children’s videos while they imitate a series of lessons. The …

A 32-Year-Old Male With Corneal Hydrops, Justin Anderson, Ryan Grinnell, Kristina Domanski, Jamie Baydoun

School of Medicine Faculty Research

A 32-year-old male with a history of left eye keratoconus presented to the emergency department with left eye pain and blurry vision for two days. Out of concern for corneal hydrops, ophthalmology was consulted, and the diagnosis was confirmed. Per ophthalmology recommendations, the patient was started on hypertonic saline and prednisolone eye drops and referred to a corneal specialist.

Multicenter Validation Of An Rna-Based Assay To Predict Anti-Pd-1 Disease Control In Patients With Recurrent Or Metastatic Head And Neck Squamous Cell Carcinoma: The Predapt Study, Kevin C Flanagan, Jessica Ley, Douglas Adkins, Eric J Duncavage, Et Al.

2020-Current year OA Pubs

BACKGROUND: Despite advances in cancer care and detection, >65% of patients with squamous cell cancer of the head and neck (HNSCC) will develop recurrent and/or metastatic disease. The prognosis for these patients is poor with a 5-year overall survival of 39%. Recent treatment advances in immunotherapy, including immune checkpoint inhibitors like pembrolizumab and nivolumab, have resulted in clinical benefit in a subset of patients. There is a critical clinical need to identify patients who benefit from these antiprogrammed cell death protein 1 (anti-PD-1) immune checkpoint inhibitors.

METHODS: Here, we report findings from a multicenter observational study, PREDicting immunotherapy efficacy from …

Interventions Aimed To Reduce Hospital Admissions In Patients With Cardiovascular Disease Related To Substance Use Disorder, Hannah Lambert, Kayla Landaverde

Master's Projects

Heart failure (HF) and substance use disorder (SUD) are both growing epidemics in the United States. When combined, patients with concurrent substance abuse and heart failure may present with various cardiac complaints such as chest pain, hypertension, and shortness of breath. There are little to few studies specifically evaluating interventions for decompensated heart failure to counteract the rising rates of cardiovascular issues associated with SUD. This review aims to investigate the effects of interventions targeted to prevent hospital readmission in patients with congestive heart failure associated with substance use disorder. An integrative review methodology was applied to gain an inclusive …

Does The Use Of Hydrotherapy And Behavioral Therapy In Addition To Pharmaceutical Medicine Reduce Chronic Back Pain In Adults?, Srujal Amin, Payton Golden

Master's Projects

Background: Chronic back pain (CBP) is a debilitating condition affecting millions worldwide, significantly impairing physical function, reducing quality of life, and imposing substantial healthcare costs. CBP is traditionally managed with pharmacological treatments, including opioids, acetaminophen, and nonsteroidal anti-inflammatory drugs (NSAIDs) which are often supplemented by prescribed physical activity to alleviate pain and improve quality of life. Recently, alternative therapies such as hydrotherapy and behavioral interventions have become more popular as safe and effective approaches to improving pain management in CBP patients. This integrative review aims to provide valuable insights into pain management, supporting healthcare professionals in developing more effective holistic …

Harris' Lead Over Trump Narrows In Nh; Likely Voters Split On Expected Winner Nationally 11/3/2024, Unh Survey Center

All UNH Survey Center Polls

Vice President Kamala Harris continues to hold a lead over former President Donald Trump in New Hampshire as the campaign comes to an end, but her advantage has shrunk since September. Voters are evenly split when asked which candidate they expect to become president, a change since September when a plurality expected Harris to win. Harris and her running mate, Minnesota Governor Tim Walz, are more popular among likely New Hampshire voters than Trump and his running mate, Ohio Senator J.D. Vance. There is widespread anxiety in the state about political violence, as more than four in five likely voters …

Whitehouse Leads Morgan In Rhode Island Senate Race; Voters Likely To Reject Constitutional Convention 11/3/2024, Unh Survey Center

All UNH Survey Center Polls

Democratic incumbent Sheldon Whitehouse leads his Republican opponent, Patricia Morgan, by double-digits in the race for the U.S. Senate in Rhode Island. Whitehouse holds a very large lead among women in the state while Morgan holds a smaller lead among men. Three-quarters of likely voters expect Whitehouse to win the contest. Rhode Islanders appear ready to reject their latest decennial opportunity to hold a constitutional convention, as momentum has swung against it in the past month. Democrats generally oppose such a convention while Independents and Republicans are divided on the issue.