Tietensä tai törkeästä huolimattomuudesta? Veronkorotuksen määrääminen verotusmenettelystä annetun lain 32.3 §:n perusteella oikeuskäytännön valossa

Tutkielmassa tarkastellaan veronkorotuksen määräämistä verotusmenettelystä annetun lain (VML) 32.3 §:n perusteella oikeuskäytännön valossa. Kyseisen pykälän perusteella määrätään ankarimmat veronkorotukset ja veronkorotus voi olla 0-30 prosenttia tuloon lisätystä määrästä. Tutkielman perusteella oikeuskäytännön valossa veronkorotus voidaan määrätä VML 32.3 §:n perusteella mikäli on osoitettavissa, että verovelvollinen on ollut tietoinen tekemästään virheestä esimerkiksi aiemman ohjauksen perusteella tai, mikäli verovelvollisen olisi pitänyt olla tietoinen tekemästään virheestä esimerkiksi asian verotuksellisen selvyyden vuoksi ja hänen voidaan tästä syystä katsoa toimineen törkeästä huolimattomuudesta. Mikäli asia kuitenkin on tulkinnanvarainen tai verovelvollinen on todistettavasti pyrkinyt selvittämään asiaa, veronkorotus ei tule määrättäväksi VML 32.3 §:n perusteella. Veronkorotus voidaan määrätä, mikäli tehdyllä virheellä on vaikutusta verovelvollisen verotettavaan tuloon ja korotuksen tulisi olla korkeintaan noin 5 prosenttia lisätystä tulosta. Oikeuskäytännön valossa verotusmenettelyn yhteydessä määrättävät veronkorotukset ovat yleisesti ottaen liian korkeita ja verohallinnon ohjeistusta tulisi tältä osin muuttaa paremmin lainsäädäntöä ja oikeuskäytäntöä vastaavaksi.

Effects of melatonin on the ovarian response to pinealectomy or continuous light in female rats: similarity with polycystic ovary syndrome

The current study was conducted to investigate the relationship between melatonin and chronic anovulation. Adult (3-4 months old) female Wistar rats were submitted to pinealectomy: group I: pinealectomized ovariectomized melatonin-treated (N = 10); group II: pinealectomized ovariectomized placebo-treated (N = 12); group III: pinealectomized light-treated placebo-treated(N = 10) or maintained under continuous light; group IV: maintained under continuous light, ovariectomized melatonin-treated (N = 22); group V: maintained under continuous light, ovariectomized placebo-treated (N = 10); group VI: maintained under continuous light placebo-treated (N = 10). In order to assess ovarian modifications, unilateral ovariectomy was performed during the fourth month in groups I, II, IV, V and the other ovary was removed after 8 months. Ovariectomy was performed in groups III and VI only after eight months. Melatonin (200 µg/100 g body weight) dissolved in 0.02 ml absolute ethanol was injected intramuscularly daily during the last 4 months into groups I and IV. The other groups were treated with placebo (NaCl). The ovarian cysts were analyzed and their area, perimeter and maximum diameter, as well as the thickness of the ovarian capsule were measured. Daily colpocytological smears were performed throughout the study. Persistent estrous condition and ovarian cysts were observed in all groups. In pinealectomized rats the ovarian and vaginal alterations disappeared at the end of the study and in rats maintained under continuous light the vaginal and ovarian polycystic aspect was reversed only in those treated with melatonin. We conclude that melatonin may act on the ovarian response reverting chronic anovulation induced by pinealectomy or continuous light.

Lesion of the subthalamic nucleus reverses motor deficits but not death of nigrostriatal dopaminergic neurons in a rat 6-hydroxydopamine-lesion model of Parkinson's disease

The objective of the present study was to determine whether lesion of the subthalamic nucleus (STN) promoted by N-methyl-D-aspartate (NMDA) would rescue nigrostriatal dopaminergic neurons after unilateral 6-hydroxydopamine (6-OHDA) injection into the medial forebrain bundle (MFB). Initially, 16 mg 6-OHDA (6-OHDA group) or vehicle (artificial cerebrospinal fluid - aCSF; Sham group) was infused into the right MFB of adult male Wistar rats. Fifteen days after surgery, the 6-OHDA and SHAM groups were randomly subdivided and received ipsilateral injection of either 60 mM NMDA or aCSF in the right STN. Additionally, a control group was not submitted to stereotaxic surgery. Five groups of rats were studied: 6-OHDA/NMDA, 6-OHDA/Sham, Sham/NMDA, Sham/Sham, and Control. Fourteen days after injection of 6-OHDA, rats were submitted to the rotational test induced by apomorphine (0.1 mg/kg, ip) and to the open-field test. The same tests were performed again 14 days after NMDA-induced lesion of the STN. The STN lesion reduced the contralateral turns induced by apomorphine and blocked the progression of motor impairment in the open-field test in 6-OHDA-treated rats. However, lesion of the STN did not prevent the reduction of striatal concentrations of dopamine and metabolites or the number of nigrostriatal dopaminergic neurons after 6-OHDA lesion. Therefore, STN lesion is able to reverse motor deficits after severe 6-OHDA-induced lesion of the nigrostriatal pathway, but does not protect or rescue dopaminergic neurons in the substantia nigra pars compacta.

Lack of tolerance for the anti-dyskinetic effects of 7-nitroindazole, a neuronal nitric oxide synthase inhibitor, in rats

7-Nitroindazole (7-NI) inhibits neuronal nitric oxide synthase in vivo and reduces l-DOPA-induced dyskinesias in a rat model of parkinsonism. The aim of the present study was to determine if the anti-dyskinetic effect of 7-NI was subject to tolerance after repeated treatment and if this drug could interfere with the priming effect of l-DOPA. Adult male Wistar rats (200-250 g) with unilateral depletion of dopamine in the substantia nigra compacta were treated with l-DOPA (30 mg/kg) for 34 days. On the 1st day, 6 rats received ip saline and 6 received ip 7-NI (30 mg/kg) before l-DOPA. From the 2nd to the 26th day, all rats received l-DOPA daily and, from the 27th to the 34th day, they also received 7-NI before l-DOPA. Animals were evaluated before the drug and 1 h after l-DOPA using an abnormal involuntary movement scale and a stepping test. All rats had a similar initial motor deficit. 7-NI decreased abnormal involuntary movement induced by l-DOPA and the effect was maintained during the experiment before 7-NI, median (interquartile interval), day 26: 16.75 (15.88-17.00); day 28: 0.00 (0.00-9.63); day 29: 13.75 (2.25-15.50); day 30: 0.5 (0.00-6.25); day 31: 4.00 (0.00-7.13), and day 34: 0.5 (0.00-14.63), Friedman followed by Wilcoxon test,vs day 26, P < 0.05;. The response to l-DOPA alone was not modified by the use of 7-NI before the first administration of the drug (l-DOPA vs time interaction, F1,10 = 1.5, NS). The data suggest that tolerance to the anti-dyskinetic effects of a neuronal nitric oxide synthase inhibitor does not develop over a short-term period of repeated administration. These observations open a possible new therapeutic approach to motor complications of chronic l-DOPA therapy in patients with Parkinson’s disease.

Relative performance of the two hands in simple and choice reaction time tasks

There is evidence that the left hemisphere is more competent for motor control than the right hemisphere. This study investigated whether this hemispheric asymmetry is expressed in the latency/duration of sequential responses performed by the left and/or right hands. Thirty-two right-handed young adults (16 males, 16 females; 18-25 years old) were tested in a simple or choice reaction time task. They responded to a left and/or right visual target by moving their left and/or right middle fingers between two keys on each side of the midline. Right hand reaction time did not differ from left hand reaction time. Submovement times were longer for the right hand than the left hand when the response was bilateral. Pause times were shorter for the right hand than the left hand, both when the responses were unilateral or bilateral. Reaction time results indicate that the putatively more efficient response preparation by the left hemisphere motor mechanisms is not expressed behaviorally. Submovement time and pause time results indicate that the putatively more efficient response execution by the left hemisphere motor mechanisms is expressed behaviorally. In the case of the submovements, the less efficient motor control of the left hand would be compensated by a more intense attention to this hand.

Bilateral repetitive transcranial magnetic stimulation for treatment-resistant depression: a systematic review and meta-analysis of randomized controlled trials

There has been concern regarding the use of controversial paradigms for repetitive transcranial magnetic stimulation (rTMS) to manage treatment-resistant depression (TRD). This meta-analysis assessed the efficacy of bilateral rTMS compared with unilateral and sham rTMS in patients with TRD. PubMed, Embase, CENTRAL, PsycINFO, Web of Science, EAGLE and NTIS databases were searched to identify relevant studies, and randomized controlled trials (RCTs) on bilateral rTMS for TRD patients were included. The response was defined as the primary outcome, and remission was the secondary outcome. Ten RCTs that included 634 patients met the eligibility criteria. The risk ratio (RRs) of both the primary and secondary outcomes of bilateral rTMS showed non-significant increases compared to unilateral rTMS (RR=1.01, P=0.93; odds ratio [OR]=0.77, P=0.22). Notably, the RR of the primary bilateral rTMS outcome was significantly increased compared to that for sham rTMS (RR=3.43, P=0.0004). The results of our analysis demonstrated that bilateral rTMS was significantly more effective than sham rTMS but not unilateral rTMS in patients with TRD. Thus, bilateral rTMS may not be a useful paradigm for patients with TRD.

Impacts of capacity remunerative mechanisms on cross-border trade

The European ambitious targets to increase the share of renewable generation pose a challenge to the generation adequacy. Many European member states are concerned that energy-only markets alone might not be able to deliver sufficient capacity required to meet the future electricity demand and back up shortfalls of energy from renewable energy sources (RES) during periods of low wind and sun. Many EU members consider to re-design their energy-only markets and establish different forms of capacity remunerative mechanisms (CRMs) to maintain the security of supply. There is a certain concern that market design changes at the level of EU member countries might conflict with the European goal of a single market. As soon as many European markets are highly interconnected, uncoordinated CRMs might create negative crossborder effects and hinder the achievement of the Internal Electricity Market in Europe. The pros and cons of capacity markets are well examined at the national level. However, the cross-border effects of capacity markets within the European market aiming at higher integration have received less attention. This doctoral dissertation examines the cross-border effects of unilateral implementation of CRMs applying both theoretical and case study analyses. The results show that capacity remunerative mechanisms (CRMs) may cause negative cross-border effects, especially if they are implemented unilaterally.

Feocromocitoma e gravidez: Relato de caso e revisão atualizada

Resumo O feocromocitoma é um tumor da adrenal produtor de catecolaminas, sendo causa rara de hipertensão arterial na gravidez. Sua prevalência em hipertensos é de 0,2%, e em 0,002% das gestações. Acompanhamos gestante hipertensa de 24 anos, branca, tercigesta, admitida na 33ª semana com emergência hipertensiva, indicada cesárea devido a sofrimento fetal, evoluindo com edema agudo de pulmão no pós-parto imediato. Submetida à videolaparoscopia após 13 dias por dor abdominal aguda, sem achado significativo. No pós-operatório, devido à hipertensão arterial grave e refratária, suspeitou-se de feocromocitoma, confirmado por exames bioquímicos e de imagem. Realizada adrenelectomia unilateral com cura da hipertensão. A anatomia patológica e a imunohistoquímica confirmaram o diagnóstico. Concluímos que casos atípicos de hipertensão na gravidez devem ser precocemente investigados e diferenciados da pré-eclâmpsia. Apesar da baixa prevalência, o feocromocitoma na gravidez aumenta consideravelmente a morbimortalidade materno-fetal e o seu reconhecimento e tratamento precoces mudam drasticamente o seu desfecho.

Competitive Effects of Non-Controlling Minority Acquisitions – Sufficient to merit further EU merger regulation?

Partial ownership interests are a widespread phenomenon in modern corporate environment. Unless minority shareholding affords the target to exercise control over the target, they do currently not have to be notified to the European Commission under EU merger regime. However, economic research has long suggested that when linking competing or non-horizontally positioned undertakings particularly in industries with few competitors, minority shareholdings even far below the majority of shares or voting rights could lead to higher prices or lower output volumes to the detriment of consumers. The Commission has recognized this issue and proceeded to suggest an extension of the merger regime to catch also certain non-controlling minority acquisitions. Horizontal non-controlling minority shareholdings create a positive correlation between the sales revenues of the partial acquirer and target. Through the equity interest the acquirer will internalise a fraction, proportional to the financial rights attached to the shareholding, of the profit of the target. This will incentivise the acquirer to contribute to increasing the target’s business profits by increasing its own sales price (horizontal unilateral effects). When a minority stake is held in a vertically related or a conglomerate company, the minority acquirer could be allowed to hamper or eliminate the target’s rivals’ access either to inputs (input foreclosure) or customers (customer foreclosure), depending on which level of the supply chain the parties are (vertical unilateral effects). Under certain circumstances minority share acquisitions could also lessen competition because they facilitate collusion between companies active in the market (coordinated effects). Economic theory confirms that non-controlling minority shareholdings may under certain circumstances create anti-competitive effects that are unlikely to be remedies by pro-competitive effects. However, they are likely to be of less significant nature than anticompetitive effects created by full mergers. This derives fore mostly from the fact that a minority share acquirer carries all the costs associated with its unilateral action but will internalise only a fraction of the lost profits. This is likely to limit the acquirer’s incentive to raise price and the profitability of such behavior. Having in mind that the number of potentially problematic cases is expected to be next to negligible, the limited potential competitive effects of non-controlling minority share acquisitions cannot be seen to clearly merit extension of the scope of the EUMR. The system suggested by the Commission is particularly ill-fitted for such purpose given the clear lack of legal certainty and considerable administrative burden associated with it.

Political economy of preferential trade agreement: the case of bilateral asymmetric negotiation

The purpose of this paper is to analyse the political economy of preferential trade agreements based on a sequential non-cooperative Stackelberg political game between a large economy and a small one, in which the political dispute of rival lobby groups defines the unilateral stance of both governments in the first stage; and the Stackelberg "coalition-proof" equilibrium defines the free trade agreement format in the second stage. Finally, a few modifications in the initial game structure are discussed in order to enhance the small economy's negotiation power. The political economy model is applied to FTAA case.

Rationality in children: the first steps

Not all categorization is conceptual. Many of the experimental findings concerning infant and animal categorization invite the hypothesis that the subjects form abstract perceptual representations, mental models or cognitive maps that are not composed of concepts. The paper is a reflection upon the idea that conceptual categorization involves the ability to make categorical judgements under the guidance of norms of rationality. These include a norm of truth-seeking and a norm of good evidence. Acceptance of these norms implies willingness to defer to cognitive authorities, unwillingness to commit oneself to contradictions, and knowledge of how to reorganize one's representational system upon discovering that one has made a mistake. It is proposed that the cognitive architecture required for basic rationality is similar to that which underlies pretend-play. The representational system must be able to make room for separate 'mental spaces' in which alternatives to the actual world are entertained. The same feature underlies the ability to understand modalities, time, the appearance-reality distinction, other minds, and ethics. Each area of understanding admits of degrees, and mastery (up to normal adult level) takes years. But rational concept-management, at least in its most rudimentary form, does not require a capacity to form second-order representations. It requires knowledge of how to operate upon, and compare, the contents of different mental spaces.

Herbert Marcuse - anticapitalismo e emancipação

Marcuse teve no Brasil na década de 1970 uma recepção unilateral, sendo visto unicamente como guru da contra-cultura. Contra esse equívoco o artigo mostra a relação intrínseca entre teoria e prática na filosofia de Marcuse, caracterizada como uma filosofia política cuja preocupação central é a transformação radical da sociedade capitalista.

O direito real de Kant

No direito real, Kant investiga a propriedade privada de uma substância (o solo e os objetos localizados nele). No estado de natureza, somente ocorre a posse física ou empírica de um objeto externo, a partir do postulado jurídico da razão prática como uma lei permissiva, pois, do contrário, as coisas utilizáveis seriam em-si ou res nullius, mas a posse jurídica ou inteligível depende da posse comum originária do solo (que não se confunde com o comunismo primitivo), para evitar que a propriedade seja uma relação entre pessoas e coisas, como acontece na teoria do trabalho, porque todo direito exige um dever correspondente. Todavia, coisas não podem ter deveres com relação a pessoas, condição seguida da vontade unilateral do primeiro ocupante de querer o objeto e do advento de uma vontade unificada a priori do provo, que só se torna efetiva no estado civil, a única capaz de gerar uma obrigação recíproca entre todos; por isso, a posse inteligível somente é possível no estado civil, embora a posse empírica do estado de natureza tenha a presunção de tornar-se jurídica, quando ocorrer a entrada no estado jurídico e vale por comparação na espera e preparação daquele estado.

Resolución N° 25 del 26 de febrero de 2007 ¿Cuáles son los los requisitos que evalúa la Cámara de Comercio respecto de la convocatoria?

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Miss-understand-ing: design education in Ontario secondary schools : an exploration of the issues with stakeholders and recommendations for change /

For most people design is a mystery. The products of design are integrated into our daily lives to the point that design has become invisible to us. However. what is subsumed in design practice is a creative problem-solving process that is applicable as a teaching strategy as well as a method for teaching the subject of design. The purpose of this study was to inquire into the current classroom practice of Ontario Visual Arts and Technological Education teachers, understand the goals of Ontario government curriculum developers, and explore the position held by the professional design community on secondary school design education. Data for this study were collected from: (a) a textual analysis of 4 Ministry curriculum documents; (b) interviews with JO stakeholders; (c) unobtrusive observations and informal conversations conducted at 7 secondary school open house events; and (d) observation of 2 sessions of an AQ course for Design and Technology. The research design modeled the design process and was divided into 2 parts: a discovery or problem-finding phase and a discussion or problem-solving phase. The results showed that design is misunderstood and misused; it has become lost between visual arts and technology where neither program holds responsibility for its delivery; students mistake working on computers for design practice; and while there is a desire within the professional community to have a voice in secondary school design education. there is no forum for participation. The technology-driven paradigm shift taking place in society today calls for a new framework for tellching and practicing dcsign. Further research is required; howcvcr. in the meantime. secondary school educators might benefit from professional development and classroom support from the professional dcsign community.