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Roy M. SCHWARZ, Aaron M. Schwarz and the Minors, Susan and Jane Schwarz, appearing through their natural tutrix, Mrs. Frances Stern, widow of Lewis E. Schwarz, Jr., now wife of Charles R. Colbert, Plaintiffs,v.UNITED STATES of America, Defendant.
The policies in question were taken out by the decedent on his own life at various times before and during his marriage. The beneficiaries are his three sons. In March, 1946, his wife died, and six months later he assigned all his interest in these policies to his sons, who paid all the premiums thereafter. A gift tax was paid on this transfer. The decedent died in 1951. When his estate tax return was audited, the Commissioner added to his gross estate a part of the proceeds of these policies proportional to the amount of premiums paid by him. The resulting deficiency was paid under protest and is now sought to be recovered.
The policy rights are incidental. Their value is almost always less than the value of the matured proceeds rights, and, for a large part of the life of a policy, it is less than the sum of the premiums paid. The policy rights are property which may be assigned and, as such, are properly the subject of a gift tax. However, such assignment does not affect the proceeds rights. It gives the assignee the opportunity to realize the present value of the policy rights and thereby destroy the proceeds rights. But if the policy continues in force, the proceeds rights mature on the death of the insured, and the policy rights disappear, according to the original terms of the contract. Under these circumstances the transfer which began with the payment of the first premium is completed only by the death of the insured. The estate tax applies when this event occurs and death is, in fact, the \"generating source\"[6] of the full value of the policy. The policies in the present case matured according to their original terms and effected a single transfer of the proceeds rights, unaffected by the assignment of the policy rights during the life of the policies. Under the circumstances, no reason appears why this life insurance transaction is not as appropriate a subject of an indirect tax as any other transfer.
The application of the gift tax to the transfer of the policy rights and the estate tax to the transfer of the proceeds rights is neither arbitrary nor unreasonable. Cf. Helvering v. Bullard, supra. Plaintiffs' contention to the contrary is again based on a failure to consider the two types of rights created by a life insurance policy. The assignment of the policy rights was properly the subject of a gift tax in view of their actual cash value at that time and the possibility that the policies might never mature. When these policies did, in fact, mature at death, the transfer of the proceeds was taxed at a different rate under the estate tax, and, presumably, the decedent's estate was credited with the amount of the gift tax. Although the policies were transferred inter vivos, their most important provision matured only on the death of the insured. Death destroyed the inter vivos rights and vested the proceeds in the decedent's survivors. Such a transfer is indistinguishable from other testamentary dispositions constitutionally subject to estate taxation. Loeb's Estate v. Commissioner, supra; Colonial Trust Co. v. Kraemer, supra; cf. Milliken v. United States, supra.
As an alternative basis for a refund, and without citation of authority, *7 plaintiffs argue that these policies were owned by decedent and his wife as community property; that when his wife died, the naked ownership of the policy rights passed immediately to the three sons, subject to a right of usufruct in the decedent during his life; that the decedent was obliged to return this property or its cash value to his sons; and that one-half the cash value of the policies at the date of the wife's death is an obligation of decedent's estate which should be allowed as a deduction on his estate tax return. Assuming that, under Louisiana law, the policy rights in an insurance policy are the kind of property one-half of which can be held in usufruct by a surviving spouse,[7] it nevertheless appears here that these rights along with all the rest of decedent's interest in the policies were irrevocably assigned by him to his sons six months after his wife's death.
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Taking a social constructivist perspective, this paper presents a socio-cognitive framework for understanding the dynamics of mature competitive markets. Its fundamental premise is that mature competitive markets are as dynamic as emerging ones because the enactment-sensemaking cycles in which producers and consumers engage, and the constant recalibration of product conceptual systems that such activity engenders, are present in both types of markets. Furthermore, it argues that the dynamic processes unleashed by enactment-sensemaking behaviors are evident in the market stories used by producers and consumers to make sense of enacted outcomes or experiences. The value of market stories to understanding market dynamics is illustrated by a rudimentary testing a set of simple propositions. Qualitative support is found for some of the propositions, and the paper concludes by discussing several theoretical and managerial implications of the socio-cognitive perspective as it pertains to understanding and managing in mature competitive markets.
\"We definitely have all of the pieces,\" said Bonner on the potential success of the team. \"I think that we are mature, we have seniors this year, we have chemistry and I think everything is there for us to be a great team in this league.\"
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BACKGROUND: Increases in the red blood cell (RBC) degree of fatty acid desaturation are reported in response to exercise, aging, or diseases associated with systemic oxidant stress. However, no studies have focused on the presence and activity of fatty acid desaturases (FADS) in the mature RBC. STUDY DESIGN AND METHODS: Steady state metabolomics and isotope-labeled tracing experiments, immunofluorescence approaches, and pharmacological interventions were used to determine the degree of fatty acid unsaturation, FADS activity as a function of storage, oxidant stress, and G6PD deficiency in human and mouse RBCs. RESULTS: In 250 blood units from the REDS III RBC Omics recalled donor population, we report a storage-dependent accumulation of free mono-, poly-(PUFAs), and highly unsaturated fatty acids (HUFAs), which occur at a faster rate than saturated fatty acid accumulation. Through a combination of immunofluorescence, pharmacological inhibition, tracing experiments with stable isotope-labeled fatty acids, and oxidant challenge with hydrogen peroxide, we demonstrate the presence and redox-sensitive activity of FADS2, FADS1, and FADS5 in the mature RBC. Increases in PUFAs and HUFAs in human and mouse RBCs correlate negatively with storage hemolysis and positively with posttransfusion recovery. Inhibition of these enzymes decreases accumulation of free PUFAs and HUFAs in stored RBCs, concomitant to increases in pyruvate/lactate ratios. Alterations of this ratio in G6PD deficient patients or units supplemented with pyruvate-rich rejuvenation solutions corresponded to decreased PUFA and HUFA accumulation. CONCLUSION: Fatty acid desaturases are present and active in mature RBCs. Their activity is sensitive to oxidant stress, storage duration, and alterations of the pyruvate/lactate ratio. 59ce067264
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