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Unusual and discrepant ABO phenotypes are often due to genetic variants that lead to altered levels or activity of ABO transferases and consequently to altered expression of ABO antigens. This report describes eight genetic alterations found in 15 cases with reduced or undetectable expression of ABO antigens. Forward and reverse ABO grouping was performed by standard gel or tube methods. Adsorption-heat elution and saliva testing for H and A substances followed the AABB technical manual procedures. Genomic DNA extracted from whole blood was PCR-amplified to cover the entire ABO coding sequence, splice junctions, proximal promoter, and intron 1 enhancer. Amplification products were sequenced by next-generation or Sanger dideoxy methods, either directly or after cloning into a bacterial plasmid vector. Eight unreported alleles were found in the 15 cases analyzed. Alleles ABO*A(28+1C) and ABO*A(29–5G) harbor variants that alter the consensus sequence at the intron 1 donor and acceptor splice sites, respectively. The other alleles harbor variants that alter the consensus sequence at transcription factor–binding sites in the intron 1 enhancer: specifically, ABO*A(28+5792T), ABO*A(28+5859A), and ABO*A(28+5860G) at GATA-1 sites; ABO*B(28+5877T) and ABO*B(28+5878G) at a RUNX1 site; and ABO*A(28+5843A) at or near a C/EBP site. Molecular and serologic characterization of ABO alleles can help in their future identification and in the resolution of discrepancies.

Unusual and discrepant ABO phenotypes are often due to genetic variants that lead to altered levels or activity of ABO transferases and consequently to altered expression of ABO antigens. This report describes eight genetic alterations found in 15 cases with reduced or undetectable expression of ABO antigens. Forward and reverse ABO grouping was performed by standard gel or tube methods. Adsorption-heat elution and saliva testing for H and A substances followed the AABB technical manual procedures. Genomic DNA extracted from whole blood was PCR-amplified to cover the entireUnusual and discrepant ABO phenotypes are often due to genetic variants that lead to altered levels or activity of ABO transferases and consequently to altered expression of ABO antigens. This report describes eight genetic alterations found in 15 cases with reduced or undetectable expression of ABO antigens. Forward and reverse ABO grouping was performed by standard gel or tube methods. Adsorption-heat elution and saliva testing for H and A substances followed the AABB technical manual procedures. Genomic DNA extracted from whole blood was PCR-amplified to cover the entire

During one of the most famous moments of the trial of Adolf Eichmann, author and Holocaust survivor Yehiel Dinur took the witness stand in the summer of 1961 to deliver a brief and enigmatic testimony about what he termed “the Auschwitz planet.” Over the next two decades, as international Holocaust consciousness re-emerged in the shadow of the Cold War, writers, thinkers, and filmmakers would elaborate on the topography of “Planet Auschwitz,” figuring the Holocaust as an alien world at the limits of modernity. Drawing on a number of sources not always included in canons of art and theory of Holocaust memory, this article shows how the genocide of Europe’s Jews, ongoing global racial conflicts, and the penetration of the “final frontier” became overlapping sites of philosophical speculation during the 1960s and 1970s about the nature of modernity and what it means to be a human being.

The Bipartisan Budget Act of 2015 (the “BBA”) made substantial changes to the audit procedures for passthrough entities. This column discusses how partnerships and individual partners will be able to challenge penalties under the BBA procedures. The BBA repealed the prior rules for partnership audits and replaced them with a centralized regime that, in general, assesses and collects tax at the partnership level in the year that the adjustment is made. The BBA contains exceptions to the new rules, such as options to modify the adjustments through filing amended returns, or for partnerships to “push out” adjustments to the partners who were partners during the tax year that is audited. The BBA and recently issued Proposed Regulations contain provisions on how penalties will be assessed. This column discusses how partnerships and partners can each raise their defenses to penalties under the new provisions. First, an example may be helpful to illustrate the difference between a partnership and partner-level defense. If a partnership engaged in a tax shelter, but the partnership’s managing partner obtained independent opinions that the transaction was permissible, the partnership itself may have a reasonable cause defense to penalties based on reliance on the advice of a tax professional. If, however, the partnership’s reliance was not reasonable because the advisor also was a promoter of the transaction, the partnership will be liable for the penalties, but an individual partner may still have his or her own defense if he or she obtained a separate opinion from an independent and competent advisor.

Under the injunction statutes in the Internal Revenue Code, the U.S. government has broad discretion to seek—and the federal courts to order—the injunction of the preparation of false or fraudulent returns, as well as the aiding and abetting of false tax returns, and the promotion of abusive tax shelters. This power includes enjoining persons and businesses from engaging in specific conduct, and other equitable remedies, such as requiring preparers and promoters to turn over their clients’ identities, notify their clients of the injunction, and disgorgement of fees. The injunction statutes provide a powerful civil enforcement tool for the Department of Justice and the IRS. In many ways, the injunction action is a much worse consequence for a tax promoter or preparer than civil penalties because the action is part of the public record (unlike the results of a preparer or promoter audit, which would be subject to taxpayer confidentiality under Code Sec. 6103), and the court may shut down the preparer’s practice altogether. This column discusses the injunction statutes and two recent cases filed against alleged tax shelter promoters.

In January 2018, the IRS published procedures to begin enforcement of Internal Revenue Code (IRC) section 7345, which requires the State Department to deny the application for, or revoke the passport of, any individual whom the IRS certifies as having a “seriously delinquent tax debt.” IRC section 7345 was enacted on December 5, 2015, as part of the Fixing America’s Surface Transportation Act (FAST Act). Prior to January 2018, the IRS had not been enforcing IRC section 7345, and there were many questions about how the passport revocation/denial process would work, such as whether there would be any additional exceptions, how the IRS would exercise its discretion, and how the IRS would interact with the State Department. Recently, the IRS has answered many of these questions through the issuance of Notice 2018-01 (Jan. 16, 2018), new Internal Revenue Manual (IRM) provisions, and updates on its website. Now that the IRS has procedures in place to enforce IRC section 7345, it is important for CPAs to advise individual clients about this new and very serious consequence to being noncompliant with their tax liabilities. Below is a description of the provisions of IRC section 7345 and the IRS guidance, followed by answers to common questions that affected individuals may have.

The Bipartisan Budget Act of 2015 (the “BBA”) made substantial changes to the audit procedures for passthrough entities. The BBA repealed the prior rules for partnership audits and replaced them with a centralized regime that, in general, assesses and collects tax at the partnership level. Tax professionals have expressed concern that assessment and collection of tax at the partnership level is inconsistent with the long-standing rules of taxation of passthrough entities, and may have unpredictable and incongruous consequences. Not surprisingly, one of the first questions that partners and practitioners asked was “how do we get out this?” Treasury and the IRS, however, want most partnerships to be covered by the BBA, and thus the election out rules have been a controversial aspect of the BBA.

Under the new Bipartisan Budget Act of 2015 (the “BBA”), there are significant changes to the partnership audit rules, including changes to the procedures for assessment and collection of tax, and for judicial review.This column focuses on one specific procedural change, the elimination of the Tax Matters Partner (TMP), and the creation of the new Partnership Representative (PR).

Practitioners who are “material advisors” with respect to “reportable transactions,” are required to report to the IRS, and to maintain information about, those transactions, and are subject to onerous penalties if they fail to comply. The definition of a “material advisor” is complex, and it is helpful to break it down into its components. However, if there is any question as to whether you are a material advisor, rather than parsing these definitions, and potentially ending up on the losing side of the argument with the IRS years down the road, consider protectively filing the required reports and maintaining lists.

If you are preparing, or advising on, the filing of amended returns or other claims for refund, one of the most important things to consider is the variance doctrine, and how it could impact your client’s ability to bring a refund action in court if the IRS denies the claim. This column focuses on the requirements of Code Sec. 7422(a) and Reg. §301.6402–2, which establish what is known as the “variance doctrine.”

This column discusses and summarizes the rules for interpreting and enforcing closing agreements between the Internal Revenue Service and Taxpayers. This column also discusses the decision in Davis v. United States, 811 F.3d 335 (9th Cir. 2016), in which the Court of Appeals allowed an assessment of tax to stand even though the IRS conceded it had breached its own closing agreement.

When a CPA discovers a taxpayer’s past noncompliance, there are both ethical and practical questions to answer. The last thing a CPA should want to do in this situation is turn a manageable issue into a serious problem. This article addresses the standards under Circular 230 and the AICPA Statements on Standards for Tax Service, as well as other basic principles to follow in deciding how to address past noncompliance by clients and how to handle the filing of tax returns that are currently due.

This article discusses when a result in a prior IRS audit can be a defense to penalties in a later year. This article reviews the recent decision of Brinks Gilson & Lione v. Comm’r, T.C. Memo. 2016-20, and J.J. Powell, Inc. v. United States, 125 Fed. Cl. 73 (2016), and provides some practice tips for successfully defending against penalties based on a favorable result in a prior audit.

Broadly accessible, low cost, accurate, and easy-to-use energy auditing tools remain out of reach for managers of the aging U.S. building population (over 80% of U.S. commercial buildings are more than 10 years old*). concept3D and NREL's commercial buildings group will work to translate and extend NREL's existing spreadsheet-based energy auditing tool for a browser-friendly and mobile-computing platform. NREL will also work with concept3D to further develop a prototype geometry capture and materials inference tool operable on a smart phone/pad platform. These tools will be developed to interoperate with NREL's Building Component Library and OpenStudio energy modeling platforms, and will be marketed by concept3D to commercial developers, academic institutions and governmental agencies. concept3D is NREL's lead developer and subcontractor of the Building Component Library.

Active noise control systems currently in use and/or described in the research literature are typically based on adaptive signal processing theory or, equivalently, adaptive feedforward control theory. This paper presents a modern control approach to the problem of active noise cancellation in a three-dimensional space. The controller is designed based on a direct self-tuning regulator. Two forms of adaptive control, namely, pole placement and minimum variance controls are considered and compared in simulation. An implementation of the adaptive minimum variance controller is used to successfully attenuate a harmonic disturbance in a laboratory setting.

A self-organizing controller based on fuzzy set theory is applied to the problem of building temperature and lighting control. A three-level hierarchical controller composed of supervisor, coordinator, and local levels is employed. The intelligent control structure is designed to maximize occupant comfort while minimizing energy usage. Fuzzy sets representing zone occupancy, utility cost, and building dynamics are used as inputs to an adaptive fuzzy relation algorithm which generates local controller setpoints. Implementation of the controller in an office building is discussed.

Complexity of dynamic systems has manifested the need for design of new controllers that have abilities beyond those provided by the existing conventional control theory. The need for qualitative methods to model and analyze complex, uncertain, nonlinear, and high dimensional systems presents the first challenge in forming an intelligent control system (ICS).

A previously described strain gauge device for continuously recording organ weights in vivo is applicable to the investigation of vascular responses in the liver and small intestine of the dog, ind...

It is recognized that present-day techniques of intracardiacsurgery demand a satisfactory method of elective cardiac arrest. Potassium citrate, acetylcholineand hypoxic arrest have allbeen used with varying degrees of success.Each of these methods has its limitations and with each, difficulties in resuscitationare encountered. In general,because of the greater ease of resuscitation,hypoxic arrest seems preferableto potassium citrateor acetyicholine.Our previous studies’suggest that hypothermia offerssome degree of protection to myocardial metabolism by preserving sources of energy for myocardial contraction. It was demonstrated that when the dog’s heart was permanently arrested at normothermia with potassium citrate, myocardial glycogen values decreased by 78 per cent, ATP by 60 per cent and lactic acid increased by 500 per cent by the end of 90 minutes of arrest. When animals were placed on cardiopulmonary by-pass and arrest produced with potassium citrate or hypoxia for 30 minutes these changes were of the same order. When total body hypothermia was utilized with by-pass, however, with myocardial temperature reduced below 20CC., glycogen values were essentially unaltered and lactic acid increased to a less degree. Adenosine triphosphate and phosphocreatine values were less consistent, but some degree of protection by hypothermia was suggested. These results are similar to those recently presented by Gott.’ Cardiac resuscitation after arrest with potassium citrate or hypoxia has been shown to be poor after periods of 20 minutes. When hypothermia was utilized with arrest, resuscitation was accomplished in all cases with ease. Therefore, these biochemical studies correlated well with the observation that the heart behaves better functionally when hypothermia is used. Since the more complicated cardiac defects often necessitate cardiac arrest for prolonged periods of time, it seemed desirable to study further the protection afforded by hypothermia when used with cardiopulmonary by-pass and hypoxic arrest, and to establish the length of time over which this protective effect might be effective. Methods Mongrel dogs, weighing 12-15 kg., were placed on cardiopulmonary bypass with a Kay-Cross disc oxygenator and a DeBakey roller pump. Right thoracotomy was performed through the fourth intercostal space.

The Zollinger-Ellison syndrome was seen in a nine year old Negro boy. This is the youngest case recorded. He was treated by total gastrectomy seventeen months ago, even after a liver metastasis was proved by biopsy. He now appears to be well in all respects.

FISTULAS between arteries and portal veins are uncommon. Reported in the literature are 5 such cases of the hepatic artery and portal veins,1 2 3 4 5 8 of the splenic artery and vein6 7 8 9 10 11 1...