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Statutes Governing Property Assessment and Taxation Program Description The Office of Policy and Management (OPM) has limited authority in the area of property assessment and taxation. OPM issues guidelines for property tax exemption and tax credit programs for which municipalities receive state reimbursement for their tax losses. OPM determines annual personal property taxes for certain companies that provide telecommunications services. OPM also prescribes the application that a taxpayer uses to obtain maritime heritage land classification. OPM staff members do not have the authority to waive property taxes or the interest on delinquent property taxes. They do not have the authority to override a determination that a local assessor or tax collector makes, nor do they issue legal opinions about property assessment and taxation legislation that town officials administer. Because property taxation affects the vast majority of Some explanations contain references to Chapters of the Connecticut General Statutes and statutory section references. Links to these chapters are available . Chapter 201 - State and Local Revenue Services; Department of Revenue Services Chapter 203 - Property Tax Assessment Chapter 204 - Local Levy and Collection of Taxes Chapter 204a - Property Tax Relief for Elderly Homeowners and Renters and Persons with Permanent Total Disability 2010 State Legislation Impacting Municipal Assessment and Taxation A compilation of pertinent sections of public and special acts that the Connecticut General Assembly enacted in 2010 is available. 2010 State legislation Impacting Municipal Assessment and Taxation (PDF) The following information is merely a general guide to state laws affecting property assessment and taxation. Waiver of Taxes or Interest Taxes; Correcting Clerical Mistakes and Obtaining Refunds; Real Estate; Personal Property; Motor Vehicles; Property Tax Exemptions, Abatements, and Credits Connecticuts Property Tax Framework There are 169 cities and towns in Local governmental officials administer the property assessment and taxation. State law governs the manner in which a town or city assessor determines property assessments and the procedures that tax collectors use to collect property taxes. State law also authorizes property tax exemptions, credits and abatements. Some cities and towns contain specific taxing districts, such as fire districts, that provide services that the city or town does not provide. The assessment of property that a city or town assessor determines is the basis for the tax that a district collects. In The grand list is a record of all taxable and tax exempt property in a taxing jurisdiction as of the assessment date. Assessors generally file the grand list by the end of January, but some may do so by the end of February. If the assessment of real estate or personal property other than a motor vehicle increases from one assessment date to the next, an assessor must send an increase notice to the affected taxpayer (Chapter 203 - Sec. 12-55). A taxpayer who disagrees with an assessors determination regarding an assessment has the right to submit a written request for a hearing to a local board of assessment appeals (Chapter 203 - Sec. 12-111). The date for submitting a hearing request is either February 20 or March 20, depending on when the grand list is completed; hearings occur in March or April. Boards of assessment appeals also meet at least once during the month of September to hear appeals related to motor vehicle assessments (Chapter 203 Sec. 12-112). A taxpayer must appear at a hearing before the board of assessment appeals, or must ensure that someone appears on the taxpayers behalf (Chapter 203 Sec. 12-113). If a taxpayer disagrees with a determination of a board of assessment appeals, the taxpayer may file an appeal with the superior court for the judicial district in which the property is located (Chapter 203 Sec. 12-117a). After the board of assessment appeals finalizes determinations for hearings held in March or April, a taxing jurisdiction determines the amount of property tax revenue that it will need for the upcoming fiscal year and sets a mill rate. Multiplying the mill rate (the basis for which is a thousandth of a dollar) by a propertys net assessment results in the property tax. The net assessment of a property is the assessment minus all exemptions for which a taxpayer qualifies. Although a taxpayer establishes a property tax liability as of October 1, a tax collector does not mail a tax bill for that liability until the following June. (A tax collector may mail a tax bill even later if there is a delay in establishing the mill rate.) Also, tax collectors do not mail tax bills for some motor vehicles until the following January. While state law requires tax collectors to mail tax bills, it also specifies that a tax collectors failure to do so does not invalidate the tax (Chapter 204 - Sec. 12-130). Local jurisdictions determine whether property taxes are due in one or more installments. State law provides a 30-day grace period for a property tax payment (Chapter 204 - Sec. 12-142). If a taxpayer pays a tax after the 30-day grace period, the payment is delinquent. State law requires tax collectors to add interest, at the rate of 1 ½ percent per month or any portion of a month, to a delinquent tax bill (Chapter 204 - Sec. 12-145). For example, a tax due July 1 is payable on or before August 1. If the tax is paid August 2, interest equals 3% (1 ½ percent for July and 1 ½ percent for August). Interest becomes part of the property tax when a tax collector imposes it. Tax collectors cannot accept a partial payment of a delinquent tax that is less than the total of the accrued interest on the principal of the tax. Each payment reduces the interest before reducing the principal (Chapter 204 - Sec. 12-145). Tax collectors may issue tax warrants to collect outstanding property taxes (Chapter 204 - Sec. 12-135). They may initiate foreclosure proceedings with regard to delinquent real estate taxes (Chapter 204 - Sec. 12-157). They may report taxpayers who are delinquent in paying motor vehicle property taxes to the Department of Motor Vehicles, in which case the taxpayer cannot obtain a registration or registration renewal without providing proof of payment of the outstanding tax. Municipalities may refer delinquent taxpayers to collection agencies and may also use other means to collect taxes that are delinquent. State law allows for the collection of property taxes within 15 years after a tax due date (Chapter 204 - Sec. 12-164). Waiver of Taxes or Interest Taxes The chief elected official of towns, cities and boroughs may abate a tax or interest for a person who is poor and unable to pay, or for a railroad company under certain circumstances (Chapter 204 - Sec. 12-124). A municipalitys legislative body (or its board of selectmen in a town in which the legislative body is a town meeting) may abate the property tax for an owner-occupied residential dwelling, to the extent that the tax exceeds 8% or more of the total income of all occupants (Chapter 204 - Sec. 12-124a). A tax collector may waive the interest on delinquent property taxes if the tax collector and the assessor, jointly, determine that the delinquency is attributable to an error by the tax assessor or tax collector and is not the result of any action or failure to act on the part of the taxpayer (Chapter 204 - Sec. 12-145). Also, state law requires a municipality to waive interest on a delinquent tax for any taxpayer who received compensation from the State of Correcting Clerical Mistakes and Obtaining Tax Refunds An assessor has the authority to correct a clerical error or omission in a property assessment within the time period that state law allows (Chapter 203 Sec. 12-60). An assessor also has the authority to issue a certificate of correction regarding personal property within a specified time period and to issue corrections regarding certain motor vehicles (Chapter 203 Section 12-57). If a correction occurs after a tax payment is made, a taxpayer may send a written request for a refund of an overpayment to the tax collector, not later than three years from the date the tax was due (Chapter 204 Sec. 12-129). State law provides a more extensive time period for the recovery of a tax overpayment by a member of the Real Estate Real estate is all land and all improvements on or to land (such as buildings, fences, and paved driveways), as well as easements to use air space (Chapter 203 - Sec. 12-64). With the exception of certain classified land, the assessment of each parcel of real property represents 70% of its estimated fair market value as of the date of a revaluation (Chapter 203 - Sec. 12-62, Sec. 12-62a and Sec. 12-63). Assessors value classified farm, forest, open space and maritime heritage on the basis of use, rather than on a fair market value basis (Chapter 203 - Sec. 12-107b through Sec. 12-107f and Public Act 07-127). When a revaluation occurs, an assessor establishes the current fair market value of all real estate, in order to equalize the tax burden among property owners. While assessors must revalue all real estate not later than five years after the October 1 effective date of the previous revaluation, they may revalue real estate more often than once every five years (Chapter 203 - Sec. 12-55 and Sec. 12-62). Before a revaluation becomes effective, taxpayers may receive questionnaires so that they may verify information concerning their properties. At least once in every 10 assessment years, an assessor (or an assessors designee) may request a taxpayers permission to enter a building, in order to verify its condition and other information the assessor needs to establish its fair market value (Chapter 203 - Sec. 12-63). State law also imposes reporting requirements that affect owners of certain income-producing real estate in conjunction with revaluations (Chapter 203 - Sec. 12-63c). Cities and towns may choose to phase in real estate assessment increases when implementing a revaluation. They may phase in all or a portion of the increase for up to five years (Chapter 203 Sec. 12-62c). Upon the completion of new construction (including building additions) in any year after the effective date of a revaluation, a taxpayers property assessment increases. The increase represents the portion of an assessment year during which the newly constructed improvement may be used for its intended purpose (Chapter 203 - Sec. 12-53a). Under certain circumstances, a real estate assessment reduction may occur during an assessment due to the demolition of a building (Chapter 203 - Sec. 12-64a). Personal Property In general, personal property is anything that is moveable and is not a permanent part of real estate, including items such as business-owned furniture, fixtures, machinery or equipment, as well as horses and unregistered motor vehicles and snowmobiles that anyone owns (Chapter 203 - Sec. 12-71). A taxpayer must file a Personal Property Declaration with the assessor of the city or town in which personal property is subject to taxation by November 1, annually (Chapter 203 - Sec. 12-41). An assessor may grant a taxpayer an extension of up to 45 days to file a declaration (Chapter 203 - Sec. 12-42). Nonresident taxpayers must file a declaration (Chapter 203 - Sec. 12-43). Lessees of personal property must also file a report with assessors by November 1, annually. This requirement affects any personal property (other than a On a Personal Property Declaration, a taxpayer provides information concerning the year of acquisition of personal property, as well as the original cost of acquisition, freight and installation. Assessors apply depreciation to the total cost a taxpayer declares to obtain the depreciated value of personal property. The assessment of the property is 70% of the depreciated value. If a taxpayer files a Personal Property Declaration subsequent to the date it is due, the assessor adds a 25% assessment penalty to the taxpayers assessment. A 25% assessment penalty is also applicable if a taxpayer fails to file a declaration, in which case an assessor uses the best information available to determine the value of the taxpayers personal property (Chapter 203 Sec. 12-41 and Sec. 12-42). An assessor (or an assessors designee) may conduct an audit regarding a taxpayers personal property. If an audit reveals that a taxpayer omitted property from a declaration or did not accurately report personal property costs, state law provides for a 25% assessment penalty. Interest is applicable to the tax for such property from the tax due date for the assessment year to which the audit relates (Chapter 203 Sec. 12-53). Motor Vehicles In general, motor vehicles are subject to taxation in the city or town where, in the normal course of their operation, they most frequently leave from and return to or remain, although state law provides some exceptions to this general rule (Chapter 203 Sec. 12-71). The assessment of a motor vehicle is 70% of its average retail value. Generally, assessors use average retail values that the National Automobile Dealers Association (NADA) compiles annually. Assessors are responsible for determining the value of any motor vehicle for which the NADA Guide does not provide an average retail value. All motor vehicles a taxpayer owns on an assessment date are subject to taxation, regardless of whether the Department of Motor Vehicles issues a A property tax reduction or credit is available when a taxpayer sells a motor vehicle and does not replace it with another vehicle. If a taxpayer replaces one vehicle with another, the assessor reduces the assessment of the replacement vehicle on the supplemental grand list to reflect the credit (Chapter 203 - Sec. 12-71b). A property tax reduction or credit is also available for a totally destroyed vehicle and for a vehicle that a taxpayer registers in another state when the taxpayer becomes a resident of that state during an assessment year. Taxpayers must claim this credit within the time period that state law prescribes (Chapter 203 - Sec. 12-71c). Property Tax Exemptions, Abatements and Credits State law authorizes various property tax exemptions for Some property tax exemptions are available only in a city or town that authorizes them via adoption of an ordinance (Chapter 203 Sec. 12-81n through Sec. 12-81bb). Property tax abatements may also be available for certain types of new construction or rehabilitation in areas of cities or towns (Chapter 203 - Sec. 12-65 to Sec. 12-65h) and cities or towns may also authorize tax abatements of up to 50% for certain types of property uses (Chapter 203 - Sec. 12-81m). The statutes that govern property tax exemptions set forth eligibility and application filing requirements. Property tax credits are available to income-eligible elderly and totally disabled homeowners; the State of The State of Previous Years
2009 State legislation Impacting Municipal Assessment and Taxation (PDF) 2008 State legislation Impacting Municipal Assessment and Taxation (PDF) 2007 State legislation Impacting Municipal Assessment and Taxation (PDF)
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Thomas Richard Coughlin is the head coach for the New York Giants, the 2007 NFL Champions. He was also the inaugural head coach of the Jacksonville Jaguars. He was head football coach at Boston College before moving to the pros. His son-in-law, Chris Snee, currently plays for him on the Giants.
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(424 quotes found)
"For a long way into the game Tim played well, he did a lot of good things. Whether he tried to press, whether he tried to do more than he should have ... . I'm not disappointed in the way Tim played, but I was looking for a continuation of the kind of start he made."
Tom Coughlin
"We're back to Square One on punt returns."
"We had some tempo in our disguise defensively."
"Our defense played aggressively and had good pressure all night."
"For someone so concerned with ball security, it wasn't a good job."
"That was disappointing, no doubt. We practice the ball on the minus-1 all the time. We had some confusion. But that's how you win and lose in this league."
"He threw for greater distance and felt good about that. He also threw a few more passes than yesterday and didn't have any discomfort at all, which is a good sign."
"You know what? ... I was consumed with trying to win the game. It's unfortunate, but you have to remember our passing game wasn't very good."
"Any time there's a player of that caliber out there, you have to give it due diligence. Beyond that, we haven't done a whole lot of discussing it."
"You can see there's some rust out there."

subset: commoncrawl


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The Arkansas Game and Fish Commission�s maintenance shed, clubhouse and dog training facilities at the Camp Robinson Special Use Area were destroyed by Sunday�s tornado at Mayflower, the commission announced in a press release Monday morning.
Other area AGFC facilities such as the H.C. �Red� Morris Natural Resources Conservation and Enforcement Training Center and the Dr. James E. Moore Jr. Camp Robinson Firing Range were not hit by the tornado.
All events at the facilities are cancelled until further notice.
The Camp Robinson SUA facilities house the agency�s maintenance equipment and tool shed. A dog training facility also was destroyed. Hunting dog enthusiasts use the facility to train bird dogs, rabbit dogs and waterfowl retrievers. A small campground is located at the facility. There were no campers on the area at the time of the tornado. The area manager�s home also was damaged by the tornado. He and his family were able to reach a storm cellar and were not injured.
Many trees are down on the 4,029-acre management area. The SUA is located approximately nine miles east of Conway adjacent to Lake Conway on Clinton Road. The area is composed of grasslands, oak savanna, an upland oak and hickory forest as well as bottomland hardwood forests.
The property was previously part of Camp Joe T. Robinson before being deeded to the AGFC for conservation purposes. Camp Robinson SUA is intensively managed for bird dog training and field trials and hosts numerous local and national events each year as well as providing numerous other outdoor, hunting, fishing and wildlife viewing opportunities. Other features of the area include an auto tour, archery range, waterfowl retriever pond and a full service shooting range. The area provides campsites with water and electricity adjacent to horse barns and dog kennels as well as a primitive campsite near the lake.
In response to the tornado, the agency�s Disaster Response Team, along with local wildlife officers, have been deployed to the area in support of local enforcement agencies. The DRT consists of about 40 wildlife officers from the AGFC�s Enforcement Division.
- GateHouse Media
Tornado destroys AGFC facilities at Camp Robinson
Apr 28, 2014 at 11:46 AM
Apr 28, 2014 at 11:46 AM


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Free Chorus (158mb)
Here's a lovely water triangle to ease your stressful lifestyle.
One of the best waveforms on the Roland MC-307 is this looped sample of running water, I superimposed it against a triangle from the system 100 here. I might do a whole library like this, natural recordings against analog waveforms..


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New Trends
The whisky industry is more dynamic now than any time in the past 50 years. Here's what's happening, what you can learn from it, and how you can benefit.
Eliminating age statements
The whisky in a bottle can't be any younger than the age on the label. Many distillers are now shunning age statements on their labels. This is significant right now, given that many young whiskies will be entering the market over the next several years due to recent increases in production levels. Distillers will be blending barrels of young whiskies with older whiskies, and they don't want to be forced to put a young age statement on the label. Instead of an age statement, look for the whisky to be given a creative name instead.
Going natural
Many whiskies are caramel colored. Why? To make young whiskies look old, and also to maintain a consistent color from one bottling to the next. The problem is, most experienced whisky tasters swear they can taste this additive and that it masks some of the whisky's true flavor.
Additionally, most whiskies are "chill-filtered." This prevents the whisky from getting cloudy when you add ice or cold water to it. What's wrong with this? Well, the components that are being removed also contribute to the whisky's flavor.
Some distilleries are now eliminating caramel coloring and chill-filtering to ensure that the whisky tastes the best it possibly can. Your clue? The whisky might be very light in color, and it may look hazy—or even a bit cloudy. The distiller often notes on the label that the whisky is not chill-filtered (or caramel colored).
Artisan distilling
Do you remember the evolution of the craft beer movement in the 1980s and 1990s? Well, we are now experiencing the whiskey version of this. In the United States alone, there are hundreds of small artisan distillers making whiskey. Many of these new startups were originally breweries. Some distillers are actually buying their "beer" from brewers, thus focusing their efforts primarily on distilling and aging. Because this industry is still young, so are many of their whiskeys.
New distilling countries
Until the past decade or so, nearly all the world's whiskies were produced in Scotland, the United States, Ireland, Canada, or Japan. Now, high-quality whiskies are being produced worldwide – including India, Sweden, Wales, Australia, and a majority of European countries. Most resemble the "scotch" style, but put their unique signature on their whisky by tweaking the whisky-making process with something different (e.g., aging in unusual casks or using non-traditional grains).
"Designer" whiskies
Some distillers are making very small quantities of time-intensive, high-cost, high-quality whiskies. They're using the finest wood, the best barley, the purest water, etc., and carefully monitor them through each phase of their production life.
Imagine a child growing up in the best surroundings, with the most loving parents, the best clothing, first-class health care, and the finest education. This is the whisky equivalent (with a price tag to match).
Blends of malts
As I mentioned above, Scotch whiskies are usually either single malt or blended (containing combinations of single malt and grain whisky). However, there's a tiny, emerging, and often misunderstood category of whiskies made only from single malts from different distilleries, with none of the lighter grain whiskies added. They are richer and more flavorful than blended whiskies. (They have, in the past, been referred to as "pure" malts or "vatted" malts.)
If you ever see a Scotch whisky being described as a "blended malt" or "a blend of malts," you'll now know what this means.
Read More — Understanding Whisky | Scotch | Irish | American | Canadian
Appreciating Whisky | Conducting a Whisky Tasting | New Trends


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Two weeks before the Iowa GOP Straw Poll -- a non-binding popularity contest for 2012 Republican presidential hopefuls -- many of the party's activists have yet to commit to any candidate.
For some, it's a dilemma of too many good choices.
"We have a lot of good candidates," says Cathy Grawe of Coralville. "We're all struggling because they are good candidates with good positions."
For others, it's a problem of not enough choices.Well short of Rick Perry possibly getting in, many Iowans may have to suck in their gut and choose from the group that is already announced. Palin and Perry won't get in, they're having to much fun playing pretend candidates.
Iowa City GOP activist Deb Thornton doesn't think Republicans are "waiting for a savior," but says the race remains wide open. She thinks a lot of people will decide the day of the straw poll.
With 20 percent of Iowa Republicans "undecided," that could happen, says Steffen Schmidt, ISU political science professor.
"It's not clear if they will attend and thus produce a surprise or if they'll stay home and harvest their summer vegetable garden," Schmidt says.As to "Where is the Passion"? If Iowans do decide to stay home and tend their vegetables instead, The passion might turn up and bite them on the a....in the form of Paulites. If Iowans can live with that, so be it.
Read the full story HERE.


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May Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts
The May § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 1.6% (up slightly from the 1.4% rate in January, February, March and April). The applicable federal rate ("AFR") for use with a sale to a defective grantor trust, self-canceling installment note ("SCIN") or intra-family loan with a note of 9-year duration (the mid-term rate, compounded annually) is 1.30% (up slightly from the April rate of 1.15%). Remember that lower rates work best with GRATs, CLATs, sales to defective grantor trusts, private annuities, SCINs and intra-family loans. The combination of a low § 7520 rate and a decline in the financial and real estate markets presents a potentially rewarding opportunity to fund GRATs in May with depressed assets you expect to perform better in the coming years.
Clients also should continue to consider "refinancing" existing intra-family loans. The AFRs (based on annual compounding) used in connection with intra-family loans are 0.28% for loans with a term of 3 years or less, 1.30% for loans with a term of 9 years or less and 2.89% for loans with a term of longer than 9 years.
Thus, for example, if a 9-year loan is made to a child and the child can invest the funds and obtain a return in excess of 1.30%, the child will be able to keep any returns over 1.30%. These same rates are used in connection with sales to defective grantor trusts.
Wandry v. Commissioner, T.C. Memo 2012-88 (3/26/2012)
In Wandry, a groundbreaking Tax Court case, the court approved a donor's use of a defined value clause (a clause where the donee is entitled to a fixed dollar amount worth of property) which, upon an IRS revaluation of LLC membership interests, resulted in a reallocation of LLC interests to the original donor. Wandry is the latest in a series of recent cases that have approved of defined value clauses. What makes Wandry unique is that it is the first case to approve of a defined value clause where there was no charitable donee to receive part of the property.
The donors, Albert and Joanne Wandry, formed Norseman Capital, LLC (the "LLC") with their children in 2001. The family members contributed cash and marketable securities to the LLC. In 2004, the donors gifted specific dollar amounts of membership interests in the LLC. They gave $261,000 of interests to each of their four children and $11,000 of interests to each of their five grandchildren. The assignments provided that the donors were transferring a sufficient number of units in the LLC so that the fair market value of the units for federal gift tax purposes would be $261,000 per child and $11,000 per grandchild. The assignments provided further that the donors intended to have a good faith determination of the value of the units made by an independent appraiser, and that if the IRS challenged such valuation and a final determination of a different value were made by the IRS or a court of law, the number of gifted units would be adjusted accordingly, so that the value of the number of units gifted to the children and grandchildren equaled the amounts set forth above.
The donors then had an appraisal completed by an independent appraiser, which the donors' accountant used to prepare a ledger for the LLC capital accounts and the donors' gift tax returns. On the donors' gift tax returns, the donors reported a gift of $261,000 to each child and $11,000 to each grandchild. However, the schedule describing the gifts stated that each child received a 2.39% interest in the LLC and each grandchild received a .101% interest in the LLC. The accountant backed into the percentages based on the dollar amounts transferred and the LLC appraisal.
The IRS asserted that the appraisal undervalued the interests by more than 40%. In Tax Court, the IRS made three arguments.
First, the IRS argued that the descriptions of the gifts in the gift tax returns were admissions that the donors transferred fixed LLC percentage interests, rather than fixed dollar amounts. The IRS relied on Knight v. Commissioner, 115 T.C. 506 (2000). In Knight, the donors stated they had gifted a fixed dollar amount of partnership interests, but, at trial, the donors argued they had actually transferred less than the fixed dollar amount. This opened the door for the IRS to assert they had not transferred a fixed dollar amount, but rather a percentage interest. In Wandry, the Tax Court found that while the schedules to the donors' gift tax returns listed percentage interests, the gifts were still reported as fixed dollar gifts. Thus, the donors always intended to gift fixed dollar amounts.
The IRS next argued that the LLC capital accounts, which reflected gifts of fixed percentages interests, controlled the nature of the gifts. The IRS relied on case law that held that a completed gift occurred with respect to corporate stock when the corporate books were changed to reflect a change in ownership. The Tax Court rejected this argument as well, reasoning that the stock transfer cases were inapplicable, because, here, there was no dispute as to whether the gifts were completed. The Tax Court believed that the facts and circumstances of the gift determine the capital accounts of the donees, rather than the capital accounts determining the nature of the gift.
Lastly, the IRS reasoned that the assignment documents transferred fixed LLC percentage interests because the defined value clause used in the assignments was void against public policy. Relying on Commissioner v. Procter, 142 F.2d 824 (4th Cir. 1944), the IRS argued that the donors' use of the defined value clause was contrary to public policy because (1) any attempt to collect the tax would defeat the gift, thereby discouraging efforts to collect tax, (2) the court would be required to pass judgment upon a moot case, and (3) the clause would reduce the court's judgment to a declaratory judgment.
The Tax Court rejected the public policy arguments by reconfirming the distinction between the type of savings clause used in Procter (which is void because it involves a "condition subsequent" in which the donor tries to "take property back" based on IRS redetermination) and the type of defined value clauses upheld in more recent cases such as McCord v. Commissioner, 461 F.3d 614 (5th Cir. 2006), Estate of Christiansen v. Commissioner, 586 F.3d 1061 (8th Cir. 2009), Estate of Petter v. Commissioner, 653 F.3d 1012 (9th Cir. 2011), and Hendrix v. Commissioner, T.C. Memo 2011-133 (which relies on a "condition precedent" to transfer a "fixed set of rights with uncertain value").
The IRS claimed that the clause in Wandry differed from the types of clauses used in the more recent cases because the Wandry clause would operate to return property to the donors. In the recent cases, charitable beneficiaries were named as parties to the transactions, so that any revaluation by the IRS would result in business interests passing to the charities. On the other hand, revaluation in Wandry would merely reallocate percentage interests among the donors and their children and grandchildren.
The Tax Court dismissed this argument and held that there is no distinction between the Wandry-type clause and clauses that use a charitable donee. Thus, the court held for the donors, finding the defined value clause valid.
Estate of Kelly v. Commissioner, T.C. Memo 2012-73 (3/19/2012)
In Kelly, the Tax Court held that property of a family limited partnership should not be included in a decedent's estate, even though the decedent owned 100% of the stock of the corporate general partner, and a management fee was paid to the corporation which could have potentially been used to pay the decedent's living expenses.
The decedent, Beatrice Kelly, owned various real properties, including quarries, a post office and rental properties, which had been operated by her husband until his death. After her husband's death, the decedent's children helped her manage the properties as well as her financial investments. The decedent executed a Will, which included specific bequests of real estate, securities and personal items, and divided the residue of her estate equally among her children.
Several years later, the decedent's health began to decline and she was ultimately diagnosed with Alzheimer's. The decedent's children were appointed co-guardians. The children then read the decedent's Will and discovered that it would not actually divide her estate equally among them, primarily because of uneven appreciation in the decedent's assets since she executed the Will. Therefore, the children entered into a settlement agreement, agreeing to honor any specific bequests to individuals other than themselves and to divide the balance of the decedent's estate equally.
Thereafter, the children consulted an attorney, who advised them that if a child predeceased the decedent, and the child's heirs (the decedent's grandchildren) refused to sign disclaimers, the settlement agreement might not ensure an equal division of the decedent's residuary estate. Thus, the attorney proposed that the decedent create family limited partnerships, one to own the quarries and three others to own the non-quarry properties. The decedent would gift limited partnership interests in the non-quarry partnerships to her children, and would retain the entire 99% limited partnership interest in the quarry partnership. The decedent also would retain about $1.1 million of liquid assets in her guardianship account. The partnerships would be managed by a corporate general partner, to be owned entirely by the decedent. The children would be the directors and officers. The partnerships would pay the corporate general partner a management fee equal to approximately 1% of the values of the partnership assets.
The children liked the proposal and applied to a Georgia court to approve the plan. In the Georgia court petition, the children stated that the plan would save close to $3 million of estate taxes. They also stated in the petition that the management fees paid to the corporate general partner would be used to pay the operating expenses of the partnerships and to provide adequate income to the decedent to cover her living expenses. The court approved the plan and the children proceeded.
The children all provided regular services to the partnerships. The son did maintenance on the properties, one of the daughters prepared financial reports and communicated with the accountant for the companies, and the other daughter did administrative work and communicated with the attorneys for the companies. The children also held regular board meetings, at which they discussed needed repairs to the properties and approved budgets.
The decedent died less than two years after she funded the partnerships and gifted interests in the partnerships to her children. At the decedent's death, she owned 100% of the corporate general partner, the 99% limited partnership interest in the quarry partnership and a 33-35% limited partnership interest in two of the other three partnerships. The children, as executors, reported those interests on the decedent's estate tax return. The IRS assessed a deficiency of $2.2 million, asserting that the value of the assets contributed to the partnership were includible in the decedent's estate.
The Tax Court found that decedent's transfers of assets to the partnerships qualified for the bona fide sale exception, because the decedent had legitimate and significant nontax reasons for creating the partnerships, and she received partnership interests in proportion to the value of the assets transferred. The primary concern of the family was to ensure the equal distribution of the decedent's assets among the children, thereby avoiding litigation. In addition, the partnerships protected the family from legitimate liability concerns with respect to the real properties, as well as concerns regarding the effective management of the assets. The court noted that the Georgia court petition referenced estate tax savings, but found that there was no evidence that tax savings actually motivated the transaction.
The gifts of the partnership interests, on the other hand, did not qualify for the bona fide sale exception, and the IRS argued that the interests in the partnerships were includible in the decedent's estate because there was an agreement for her to retain income from the partnerships. The IRS pointed to the language of the Georgia court petition, which stated that the management fees were to be used to pay for the decedent's living expenses, in addition to the costs of operating the partnerships.
The court rejected the argument. First, it noted that the decedent and her children respected the partnerships as separate legal entities, observing their formalities, and sufficient assets were retained outside of the partnerships for the decedent's personal needs. Second, the decedent's personal expenses were never actually paid from the management fees. The language in the Georgia court petition suggesting that the fees would cover the decedent's expenses was not a legally binding directive. Moreover, for the general partner to permit the fees to be used in that manner would have violated the fiduciary duties imposed on the general partner. Thus, the court held in favor of the estate.
Estate of Turner v. Commissioner, 138 T.C. 14 (March 29, 2012)
This Tax Court case, referred to as "Turner II," is a follow-up to "Turner I," a 2011 Tax Court case, Estate of Turner v. Commissioner, T.C. Memo. 2011-209, which held that property underlying certain family limited partnership interests that were gifted by a decedent to family members during his lifetime were includible in the decedent's estate. In Turner I, the Tax Court found that there was no legitimate nontax purpose of the partnership, which consisted entirely of cash and marketable securities.
In Turner II, the estate argued that, under the decedent's Will, his surviving spouse's right to a pecuniary marital bequest (coupled with the residual bypass trust) effectively reduced the estate tax to zero. The IRS contended that, even though the partnership interests were included in the decedent's estate, neither the partnership interests nor the underlying property actually passed to the surviving spouse and, therefore, it could not qualify for the marital deduction.
The court noted that the Treasury Regulations for Section 2056 provide that a "property interest is considered as passing to the surviving spouse only if it passes to the spouse as beneficial owner." Here, neither the partnership interest nor the underlying property passed or could pass to the surviving spouse as beneficial owner.
The court also noted that, if a decedent's estate claims a marital deduction, the marital deduction presupposes that the surviving spouse will include the value of the assets in his or her gross estate (provided that the surviving spouse does not consume the assets during his or her lifetime). Here, no Internal Revenue Code provision would require the surviving spouse's estate to include the partnership interests or the underlying property. Therefore, the court reasoned that allowing a marital deduction would allow the assets to leave the marital unit without being taxed. Accordingly, the court found that the estate was not entitled to a marital deduction.
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Advances in Urology
Volume 2012 (2012), Article ID 439372, 6 pages
New Artificial Urinary Sphincter Devices in the Treatment of Male Iatrogenic Incontinence
First Department of Urology, Aristotle University of Thessaloniki, Thessaloniki 54635, Greece
Received 30 January 2012; Accepted 15 February 2012
Academic Editor: Drogo K. Montague
Copyright © 2012 Ioannis Vakalopoulos et al. This is an open access article distributed under the Creative Commons Attribution License, which permits unrestricted use, distribution, and reproduction in any medium, provided the original work is properly cited.
Severe persistent stress incontinence following radical prostatectomy for prostate cancer treatment, although not very common, remains the most annoying complication affecting patient's quality of life, despite good surgical oncological results. When severe incontinence persists after the first postoperative year and conservative treatment has been failed, surgical treatment has to be considered. In these cases it is generally accepted that artificial urinary sphincter is the gold standard treatment. AUS 800 by American Medical Systems has been successfully used for more than 35 years. Recently three more sphincter devices, the Flow-Secure, the Periurethral Constrictor, and the ZSI 375, have been developed and presented in the market. A novel type of artificial urinary sphincter, the Tape Mechanical Occlusive Device, has been inserted in live canines as well as in human cadavers. These new sphincter devices are discussed in this paper focusing on safety and clinical results.
1. Introduction
In recent years, despite improvement in the surgical technique, the prevalence of Postprostatectomy Urinary Incontinence (PPUI) has increased due to rising number of radical prostatectomies performed annually [1]. Iatrogenic-induced sphincter incompetence is the reason of postoperative stress incontinence in 95% of cases. The reported PPUI rates vary from 5% to 48%. This large variation may be attributed mainly on the influence of the interviewing physician and a lack of a standardized definition of "post prostatectomy incontinence" [2].
Noninvasive therapy and particular pelvic floor muscle training is the first-line treatment for early incontinence following prostatectomy within the first 6 to 12 months [2]. Lifestyle interventions and pharmacotherapy (duloxetine) are also recruited in this attempt [3, 4]. Despite this conservative intervention, up to 10% of patients with PPUI exhibit a persistent and moderate-to-severe incontinence for more than one year postoperatively [5]. For these patients surgical treatment is recommended [2].
The Artificial Urinary Sphincter (AUS) 800 (American Medical Systems, Minnetonka, MN, USA), despite the new surgical treatment options (slings, injection of bulking agents, stem-cell therapy), remains the gold standard for persistent moderate-to-severe stress urinary incontinence due to Intrinsic Sphincter Deficiency (ISD) [1, 2, 6]. In effort to keep the good success rates and improve some disadvantages of AUS 800 (high cost, complications, and relative difficult insertion), four new devices have been developed in recent years [1]. We attempt to present technical characteristics and insertion procedures for these devices and to report safety and efficacy data, where they are available.
2. FlowSecure TM (RBM-Med)
The FlowSecure artificial urinary sphincter is a new prosthesis for the management of urinary incontinence due to ISD that has been designed and developed by Professors Craggs M. D. and Mundy A. R. at London's Institute of Urology and Nephrology, in 2006 [7]. Unlike AUS 800, this sphincter is an adjustable prosthesis filled with normal saline without contrast. Plain X-rays cannot therefore be used for monitoring, and ultrasound scan is the adequate radiographic technique for evaluation. Except verifying prosthesis status, ultrasound also allows measuring of the postvoid residual volume and calculation of the urethral closing pressure [8]. Moreover, MRI can ensure the precise position and integrity of all components of the sphincter [9].
The FlowSecure sphincter is a one-piece device consisting of two reservoirs placed in the paravesical space, a cuff that surrounds the urethra and a control pump with a self-sealant port that is placed in patient's scrotum (Figure 1). The first reservoir regulates resting urethral pressure and the other relieves stress pressure during intra-abdominal increase. During bladder filling the cuff connected with the pressure regulating reservoir compresses and keeps the bulbar urethra closed at low pressure. When intra-abdominal pressure rises, the stress relief balloon provides additional pressure to the cuff to maintain continence. The fluid pressure of the prosthesis may be regulated by injecting or removing saline through the self-sealing port in the control pump located in patient's scrotum [10]. When the patient wishes to void he only has to press the control pump until a good urine flow is achieved. In this way the cuff is emptied by moving the fluid from it to the pressure-regulating reservoir. Redirection of fluid flow and filling of the cuff is recovered when compression on the pump stops [11].
Indications for implantation of the FlowSecure device in order of significance are postprostatectomy urinary incontinence, incontinence due to congenital abnormalities, neurogenic bladder with ISD, and women stress incontinence, where other surgical procedures have failed [9–12].
Both perineal and suprapubic access are needed for prosthesis implantation. Pressure-regulating and stress relief reservoirs are lodged in Retzius space through the suprapubic incision. The cuff is placed through the perineal incision around the bulbar urethra as it is designed to transmit direct pressure over the urethra. By blunt dissection a space is created between the two incisions to pass the tubing, as well as a subcutaneous space in the scrotum where control pump is placed. FlowSecure is accompanied by a plastic trocar and its obturator, which allows transposition of urethral cuff between Retzius space and perineum, and a tube of glue for temporary fixation of the belt over the cuff when adjusting it [11]. The control pump should be used as soon as the scrotal edema disappears. In case of persistent urinary retention, patients must be taught to perform intermittent self-catheterizations until the problem resolves. It is important that, during the catheterizations period, the patient must use the control pump to empty the cuff, even if he cannot void. The patient should be reevaluated for continence status 2 to 4 weeks after discharge. If he maintains continence, the prosthesis does not need pressurization. In those patients, who do not regain continence, pressurization of the system must be carried out. Under strict aseptic conditions, local anesthesia is administered at the scrotal area where the control pump is located. Some saline is injected through the self-sealing port using an orange 25 G 15 mm needle and a 10 mL syringe. The needle must be inserted longitudinal to the pump, to avoid damaging the device. The prosthesis pressure is directly dependant on the injected volume, following a pressure/volume curve. Ideally, the first pressurization reaches between 40 and 50 cm H2O, which normally takes about 4 to 6 mL of saline. The patient is advised to be re-evaluated two weeks after initial pressurization. At this time, fluid can be added or removed from the system to accommodate to the patient's needs. It is not advisable, during subsequent pressurization, to add more than 2 mL of saline per session [9]. Proper device function must be monitored by free uroflowmetry, ultrasound scan, and clinical history [8].
Knight et al. presented 9 male patients (mean age 66 years) with urodynamically proven stress incontinence due to radical prostatectomy treated with implantation of FlowSecure sphincter. The patients were followed for a minimum period of 12 months. All 9 patients recovered well from surgery. Two devices had to be removed for technical reasons. The mean leakage for the remaining 7 patients prior to implantation was mL corresponding to a continence index of 54%. Twelve months later the leakage had statistically significantly reduced to mL () and the continence index increased to 97%. There was no significant difference in bladder capacity or flow rate. Four patients required additional pressurization to achieve optimal continence and this was carried out without complication [13]. In another study by Rodriguez et al. 100 patients with stress urinary incontinence of various etiologies underwent bulbar urethra (96%) or bladder neck (4%) implantation of a FlowSecure device. All patients had tried conservative treatments and also 59 patients had undergone unsuccessful surgical procedures (suburethral slings, bulking agents, Proact, and AUS-800). Nine patients had undergone previous pelvic radiotherapy. At implantation the sphincters' pressure was left at atmospheric level in all cases. Patients attended for initial pressurization 2–4 weeks postoperatively and were recalled at two-week periods for evaluation and repeat pressurization, if it was required. Overall, 3 pressurizations procedures were required to achieve socially satisfactory continence in 89 patients. The implanting procedure lasted in average 38–47 minutes. Mean inpatient stay was 4.3 days. 53 patients had postoperative self-limited scrotal hematoma. Implants had to be removed in 28 patients (28%) due to early infection (8%), late infection secondary to pressurization procedures (5%), perforation of the pump at pressurization (9%), and mechanical failure (6%). No erosions were noted [14].
The main advantage of FlowSecure device over AUS 800 is that while the later exerts a high constant pressure over the urethra, the former increases pressure on the urethra instantly, only during stress increase of intra-abdominal pressure. During the deactivated position the cuff turns back to the initial low pressure not exceeding 40 cm H2O, thus minimizing danger for urethral erosion [11].
In conclusion, FlowSecure artificial urinary sphincter is easy to implant, with low risk of mechanical failure, and adjustable to the patient's continence needs. Its main purpose is to achieve total patient continence during periods of raised abdominal pressure while subjecting urethra to the lowest possible pressure during resting. Urethral ischemia potentially leading to atrophy and erosion is thus prevented [8]. Use of one-piece prosthesis also decreases the risk of infection due to intraoperative handling and minimizes the chance of mechanical failure derived from errors during assembly [13]. All these may predict a promising future. However, more time and studies will be needed to define the role of this sphincter in the management of stress incontinence resistant to other treatments.
3. Periurethral Constrictor (Silimed, Rio de Janeiro, Brazil)
The Periurethral Constrictor (PUC) was developed by Dr. Fabio Vilar in 1996. It was designed for implantation in pediatric patients to treat deficient bladder sphincter function [15]. The PUC is a one-piece, two-part device. It is comprised of a constrictor cuff linked by a 20 cm silicone tube to a valve, which is elliptical in shape and rounded at the edges (Figure 2) [16]. The adjustable cuff is implanted around the bladder neck through suprapubic approach or bulbous urethra through perineal incision [17]. The valve is placed in a space accessible by percutaneous puncture, usually in the subcutaneous space between the umbilicus and the iliac crest. The injection port is designed to accommodate a fine Huber needle [18].
The system works hydraulically by the injection of sterile saline solution through the self-sealing valve in order to promote a static occlusive pressure on the cuff. The activation of the PUC takes place 6–8 weeks after implantation surgery. This requires filling the bladder and then injecting further saline into the system for as long as the occlusive pressure obtained allows good urine flow without significant increase of the post void residual urine volume [16].
A limited number of studies with controversial results have been published for using PUC in PPUI, excluding studies focused in its use in pediatric population, especially for the treatment of neurogenic urinary incontinence due to ISD [15, 18, 19]. In a study performed by Simone et al. 43 patients with mild urinary incontinence following radical prostatectomy were treated by PUC implantation. Overall successful rate was 86%. Postoperative complications occurred in 6 patients (1 hematoma, 1 erosion, 2 infections, and 2 malfunctioning devices). Only the first two complications were managed by device removal [20]. Schiavini et al. retrospectively studied 30 patients with PPUI and PUC implantation for a mean period of 42.1 months. At the time of implantation the reported mean use of pads was 4.4 per day. In 22 patients (73.3%) the devices were functional leading to a good continence result. In 7 patients the device was removed because of cuff erosion (4 patients, 13.3%) and infection (3 patients, 10%). An eighth patient remained incontinent after the device reactivation because of detrusor hyper-reflexia [16]. On the other hand, Lima et al. presented a study with 82.2-month mean followup which reported a very high device removal rate 41.07% [17]. The average time between surgery and the removal of the device was 22.6 months. The most frequent complication was urethral erosion in 15 patients (26.78%). Comparing erosion rates of AUS 800, ranging from 1.7% to 4.5%, the present study presented higher rates [21]. Other complications were mechanical malfunction in 5 (8.9%), urethral stenosis in 3 (5.3%), urinary fistula in 2 (3.5%), infection in 2 (3.5%), and persistent urinary tract infection in 1 case (1.7%). In patients in whom the device was not removed (33), only 17 from them were continent, representing an overall success rate of 30.35% [17].
The above results, suggest that further studies are required to determine the safety and efficacy of this type of artificial urinary sphincter. However, simplicity and low cost of PUC are important characteristics in its favor comparing with AUS 800 [16]. The one-piece design makes the device easier to implant and the absence of connections reduces the chances for leakage and kinks [19]. The characteristics of the cuff allow spontaneous voiding and catheterization without the need of previous emptying the cuff. It can be deactivated, under activated or reactivated at any time by simply punctuating the subcutaneous port to add or subtract fluid [18]. Based on these observations, more studies are needed to bring safer conclusions.
4. ZSI 375 (ZEPHYR Surgical Implants, Swiss-French)
ZSI 375 is an artificial urinary sphincter produced by ZEPHYR Surgical Implants, a Swiss-French company. The system was designed and created by Dr. Christophe Gomez-Llorens and Raphael Gomez-Llorens in 2005 [22]. It is used to treat severe urinary incontinence due to ISD. The ZSI 375 is a one-piece medical device that can be implanted only in men. It is made by silicone elastomer and filled with sterile normal saline solution. It consists of an inflatable and adjustable cuff that fits around the urethra and a pump with an embedded pressure-regulating tank placed in the scrotum connected with the cuff by a 110 mm silicone tube (Figure 3). The maximal pressure in the cuff must not exceed 350 mbar. The ZSI 375 is filled by normal saline solution. There are two compartments in the device: a hydraulic circuit and a compensation pouch circuit separated by a piston. Spontaneously, the spring pushes the piston up and the piston pushes the saline solution of the hydraulic circuit into the cuff. The pressure in the hydraulic circuit is not the only factor of the cuff efficiency. To obtain a good continence result, the deflated cuff must compress the urethra. The ZSI 375 has the advantage to increase the issued pressure and give the chance to readjust the cuff [22].
Two incisions are needed for the implantation of the device. Through a perineal incision the cuff is placed around the bulbar urethra. The pump unit is placed in a subdartos pouch through an inguinal incision. Six to eight weeks later the device is activated by pressing an activation button. If necessary, it is possible to inject 1 or 2 mL of normal saline in the compensation pouch through the scrotum to increase the issued pressure [22].
The advantages of ZSI 375 over AUS 800 are reduced cost, the opportunity to adjust the issued pressure of the device, and the possibility to re-adjust the cuff in case of postoperative urethral atrophy [22].
In a study performed by Sandul et al. 34 men with urine incontinence after treatment for prostate cancer were treated by ZSI 375. Thirty-two of them had radical prostatectomy, six of those also had adjuvant radiotherapy, and two had brachytherapy followed by TURP to relieve outlet obstruction. Eight patients had already undergone a male perineal sling operation. Initial sphincter closure pressure was elected to be 60–70 cm H2O. 60% of the patients needed further increase of the pressure, something which was performed as an office procedure. The interval for primary activation ranged from 4 to 6 weeks. With a maximum followup of 20 months, no surgical revision was necessary for mechanical malfunction. Infection of the device occurred in 2 (5.8%) patients requiring device removal. Overall, social acceptable continence was achieved in 94.2% (32 patients) [23]. Llorens et al. studied 17 men, after 1 year of implantation of the ZSI 375. 14 patients were incontinent after radical prostatectomy and 3 patients after TURP. All patients had tried previous conservative treatments without success. Total continence was defined as dry, and social continence was defined as a minimal leakage requiring at the most one pad daily with activity. All other results were defined as incontinence. In14 patients the initial pressure adjusted to 60–70 cm H2O and in 3 patients to 70–80 cm H2O. Mean hospitalization duration was three days. Implantation and recovery were uneventful for 12 patients. Four patients in whom the pump unit was implanted through the perineal incision presented permanent scrotum edema making the manipulation of the pump difficult. This led to the reimplantation of the pump in a subdartos scrotal pouch through a scrotal incision. After re-implantation, one patient presented extrusion of the pump unit and the device had to be removed. Finally one patient presented infection leading to artificial sphincter removal five days after the procedure. None of the remaining 15 patients demonstrated bladder overactivity, chronic urinary retention, or any other adverse effect. According to the results the three patients implanted with 70–80 cm H2O issued pressure in the system were dry. For the 12 patients implanted with the 60–70 cm H2O issued pressure in the system, three became completely dry, three achieved social continence, and six were still incontinent using two to three pads per day. Eleven patients implanted with 60–70 cm H2O were initially satisfied with their continence results. However, after in-situ injection of one mL of saline solution in the compensation pouch, the issued pressure increased 10 cm H2O to 70–80 cm H2O and the patients improved or achieved social continence [22]. 70–80 cm H2O seems to be the most efficient issued pressure because the pressure-regulating system of ZSI 375 is not submitted to abdominal pressure.
The innovative features of the ZSI 375 are the following: it is a one-piece device thus facilitating preparation and implantation; it contains an adjustable cuff mounted in a curve to reduce creasing and fracture danger; it offers the possibility to increase the issued pressure of the device in situ achieving better continence results; finally, preparation and implantation of the ZSI 375 are technically simple and quick with no serious adverse events associated with the device [22].
5. The Tape Mechanical Occlusive Device (GT Urological, Minneapolis, MN)
A new type of artificial sphincter is being developed utilizing a spring-loaded mechanism for applying circumferential pressure in the urethra, which is easy to implant and simple to use. This artificial urinary sphincter is the Tape Mechanical Occlusive Device (TMOD) (GT Urological LLC, Minneapolis, MN), a one-piece device that is manually controlled by the patient through its ON/OFF buttons [24].
The TMOD is a totally implantable, one-piece artificial urinary sphincter (Figure 4) consisting of an occlusive tape and a conduit tape, connected to a control mechanism. The conduit tape originates at the control mechanism and the occlusive tape connects to the conduit tape. The conduit tape is of sufficient length to allow placement of the occlusive tape at the bulbous or penoscrotal urethra without creating undue tension on the conduit tape. The scrotally implanted control mechanism consists of a titanium casing, housing a three-metal alloy spring that applies tension to sutures running through the conduit and occlusive tapes. The control mechanism has ON and OFF buttons and is covered with a flexible silicone boot that prevents tissue in-growth. The boot has a port for injection of saline into the device that displaces air and creates an isotonic interior. This same port is designed for antibiotic flushing per surgeon discretion. In the ON position, the occlusive tape contracts and is designed to apply radial pressure to the urethra of 50–80 cm of water. The degree of radial pressure was chosen from clinical experience with the AUS 800 in order to limit urine leakage while minimizing urethral perfusion. There is a locking clip that locks the occlusive tape to itself to form an annular occlusive ring around the urethra. This can easily be unclipped for tape removal if repositioning or removal of the TMOD is required. Suture tabs are attached to both the control mechanism and occlusive tape to anchor the device in place and prevent migration [24].
In humans is anticipated to implant the occlusive tape in an open, deactivated condition, allowing it to remain in that condition for 6 weeks postoperatively to permit healing. The physician would then activate the device to apply pressure to the urethra by depressing the ON button through the intact scrotal skin. The patient can then depress the control mechanism OFF button to again remove occlusive pressure from the urethra and allow for unobstructed voiding or lock it in the deactivated position for voiding or nocturnal deactivation. To reactivate, the patient can push the ON button [24].
The TMOD has been implanted in canines to assess its functionality, occlusive efficiency, and biocompatibility and in human male cadavers to assess its occlusive efficiency and sizing, with encouraging results. Activation of the implanted TMOD resulted in intraurethral pressures within the desired range of 50–80 cm H2O. The device has proven to have no evidence of systemic toxicity. It has met the requirements for reliability and biocompatibility [24].
The TMOD seems to offer several advantages over the currently available AUS 800. It is a single piece device that does not require assembly reducing preparation time by operating room staff. It is nonhydraulic and requires no pressure-regulating balloon placement leading to less dissection. The reduced width of the tape minimizes the dissection around the bulbar urethra reflecting a lower risk of urethral injury during the operation. The simplicity of the ON/OFF button operation allows easier patient control. The TMOD has not been implanted in live human patients yet and human clinical trials should follow given the proof of technical feasibility, biocompatibility, and lack of systemic toxicity.
6. Conclusion
The first artificial urinary sphincter was introduced in 1973 to treat ISD [25]. After its introduction the basic device design changed to the fifth-generation model, the AUS 800, in 1983 [26]. Despite its good success rate, in order to decrease mechanical failure, numerous changes have been made to the various components of this device; however, its basic design and mode of operation have remained unchanged for over 20 years. Recently, new devices have been developed to overcome the disadvantages of AUS 800. The controversial results in success and complication rates emphasize that these new devices need to be implanted in greater numbers of patients and with longer follow-up periods. If this experience reveals that one or more of them present potential advantages, these new artificial urinary sphincters will become an important tool in the management of men suffering from PPUI owing to ISD.
Conflict of Interests
The authors declare that they have no conflict of interests.
- R. M. Bauer, C. Gozzi, W. Hübner, et al., "Contemporary management of post prostatectomy incontinence," European Urology, vol. 59, no. 6, pp. 985–996, 2011. View at Google Scholar
- A. Schröder, P. Abrams, K. E. Andersson, et al., "Guidelines on urinary incontinence," in EAU Guidelines, A. G. Arnheim, Ed., pp. 11–28, European Association of Urology, Arnheim, The Netherlands, 2010. View at Google Scholar
- P. S. Goode, K. L. Burgio, T. M. Johnson II et al., "Behavioral therapy with or without biofeedback and pelvic floor electrical stimulation for persistent postprostatectomy incontinence: a randomized controlled trial," JAMA, vol. 305, no. 2, pp. 151–159, 2011. View at Publisher · View at Google Scholar
- P. Mariappan, A. Alhasso, Z. Ballantyne, A. Grant, and J. N'Dow, "Duloxetine, a serotonin and noradrenaline reuptake inhibitor (SNRI) for the treatment of stress urinary incontinence: a systematic review," European Urology, vol. 51, no. 1, pp. 67–74, 2007. View at Publisher · View at Google Scholar · View at Scopus
- D. F. Penson, D. McLerran, Z. Feng et al., "5-Year urinary and sexual outcomes after radical prostatectomy: results from the prostate cancer outcomes study," Journal of Urology, vol. 173, no. 5, pp. 1701–1705, 2005. View at Publisher · View at Google Scholar · View at Scopus
- S. Herschorn, "The artificial urinary sphincter is the treatment of choice for post-radical prostatectomy incontinence," Journal of the Canadian Urological Association, vol. 2, no. 5, pp. 536–539, 2008. View at Google Scholar · View at Scopus
- M. D. Craggs, N. J. Chaffey, and A. R. Mundy, "A preliminary report on a new hydraulic sphincter for controlling urinary incontinence," Journal of Medical Engineering and Technology, vol. 15, no. 2, pp. 58–62, 1991. View at Google Scholar · View at Scopus
- D. A. Rodríguez, L. F. Barranco, F. García-Montes, A. M. Salvá, and M. O. Moragues, "Follow-up of the FlowSecure artificial urinary sphincter," Actas Urologicas Espanolas, vol. 33, no. 9, pp. 952–955, 2009. View at Publisher · View at Google Scholar · View at Scopus
- F. García Montes, A. Vicens Vicens, M. Ozonas Moragues et al., "'FlowSecure' artificial urinary sphincter: a new adjustable artificial urinary sphincter concept with conditional occlusion for stress urinary incontinence," Actas Urologicas Espanolas, vol. 31, no. 8, pp. 872–879, 2007. View at Google Scholar · View at Scopus
- F. García-Montes, "FlowSecure™ artificial urinary sphincter for the treatment of stress urinary incontinence after radical prostatectomy," Archivos Espanoles de Urologia, vol. 62, no. 10, pp. 845–850, 2009. View at Google Scholar · View at Scopus
- J. E. B. Vallejo, F. G. Montes, L. C. Rosell, C. M. Maresma, and J. M. Robles, "Implantation technique of the artificial urinary sphincter flow secure™ in the bulbar urethra," Archivos Espanoles de Urologia, vol. 62, no. 3, pp. 195–200, 2009. View at Google Scholar · View at Scopus
- F. García-Montes, A. Vicens-Vicens, M. Ozonas-Moragues, J. Oleza-Simo, and A. Mora-Salvá, "Surgical implantation of the new flowsecure™ artificial urinary sphincter in the female bladder neck," Urologia Internationalis, vol. 79, no. 2, pp. 105–110, 2007. View at Publisher · View at Google Scholar · View at Scopus
- S. L. Knight, J. Susser, T. Greenwell, A. R. Mundy, and M. D. Craggs, "A new artificial urinary sphincter with conditional occlusion for stress urinary incontinence: preliminary clinical results," European Urology, vol. 50, no. 3, pp. 574–580, 2006. View at Publisher · View at Google Scholar · View at Scopus
- D. Alonso Rodriguez, E. Fes Ascanio, B. L. Fernandez, V. A. Vicens, and F. Garcia-Montes, "Four years experience with the FlowSecure Artificial Urinary Sphincter. Problems and solutions," in Proceedings of the 41st Annual Meeting of the International Continence Society (ICS '11), Glasgow, UK, August 2011.
- S. V. C. Lima, L. A. P. Araújo, F. O. Vilar, C. L. Kummer, and E. C. Lima, "Combined use of enterocystoplasty and a new type of artificial sphincter in the treatment of urinary incontinence," Journal of Urology, vol. 156, no. 2, pp. 622–624, 1996. View at Google Scholar · View at Scopus
- J. L. Schiavini, R. Damião, J. A. D. de Resende Júnior, M. C. Dornas, D. S. Cruz Lima da Costa, and C. B. Barros, "Treatment of post-prostate surgery urinary incontinence with the periurethral constrictor: a retrospective analysis," Urology, vol. 75, no. 6, pp. 1488–1492, 2010. View at Publisher · View at Google Scholar · View at Scopus
- R. S. Lima, E. G. C. Barros, C. A. Souza, F. O. de Vilar, and S. V. C. Lima, "Periurethral constrictor: late results of the treatment of post prostatectomy urinary incontinence," International Brazilian Journal of Urology, vol. 37, no. 4, pp. 483–487, 2011. View at Publisher · View at Google Scholar
- F. De O Vilar, L. A. P. Araújo, and S. V. C. Lima, "Periurethral constrictor in pediatric urology: long-term followup," Journal of Urology, vol. 171, no. 6, pp. 2626–2628, 2004. View at Publisher · View at Google Scholar · View at Scopus
- S. V. C. Lima, L. A. P. Araüjo, and P. O. Vilar, "Further experience with the periurethral expander: a new type of artificial sphincter," British Journal of Urology, vol. 80, no. 3, pp. 460–462, 1997. View at Google Scholar · View at Scopus
- G. Simone, S. Guaglianone, R. Papalia, C. Leonardo, M. Ferriero, and M. Gallucci, "Periurethral constrictor (Silimed): a new device for treatment of mild urinary incontinence Following radical prostatectomy," Journal of Urology, vol. 181, supplement 4, article 619, 2009. View at Google Scholar
- A. E. Gousse, S. Madjar, M. M. Lambert, and I. J. Fishman, "Artificial urinary sphincter for post-radical prostatectomy urinary incontinence: long-term subjective results," Journal of Urology, vol. 166, no. 5, pp. 1755–1758, 2001. View at Google Scholar
- Zephyr Surgical Implants, Geneva, Switzerland, http://zephyr-si.com/zephyr/index.php?lg=en.
- A. Sandul, F. E. Martins, P. Barros, T. M. Lopes, and C. Llorens, "The ZSI 375 artificial urinary sphincter: a new device for male urinary incontinence," in Proceedings of the 7th National Congress of Portuguese Association of Neurourology and Urogynecology, Vilamoura, Portugal, November 2010.
- B. S. Malaeb, S. P. Elliott, J. Lee, D. W. Anderson, and G. W. Timm, "Novel artificial urinary sphincter in the canine model: the tape mechanical occlusive device," Urology, vol. 77, no. 1, pp. 211–216, 2011. View at Publisher · View at Google Scholar · View at Scopus
- F. Brantley Scott, W. E. Bradley, and G. W. Timm, "Treatment of urinary incontinence by implantable prosthetic sphincter," Urology, vol. 1, no. 3, pp. 252–259, 1973. View at Google Scholar · View at Scopus
- D. K. Montague, "Evolution of implanted devices for urinary incontinence," Cleveland Clinic Quarterly, vol. 51, no. 2, pp. 405–409, 1984. View at Google Scholar · View at Scopus


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SYDNEY (MarketWatch) -- Australian stocks fell sharply in early trading on Tuesday, after early polls tracking Italy's general-election results indicated a split that may trigger another election and more debt trouble for the European region. The S&P/ASX 200 index XJO, +0.80% fell 1.3% to 4,992.30 in early trading, with energy, miners and banks reeling. Commonwealth Bank of Australia CBA, +0.52% CBAUF, +6.32% dropped 1.3%, BHP Billiton Ltd. BHP, +0.29% BHP, -0.84% fell 1.7% and Woodside Petroleum Ltd. WPL, +0.55% WOPEF, -4.02% dropped 1.5%. Insurer QBE Insurance Group Ltd. QBE, +1.99% QBEIF, +8.17% fell 5.4% after the firm posted an 8% rise in 2012 net profit to $761 million which nonetheless missed company estimates.
Read the full story: Asia stocks tumble on messy Italian vote results


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Hi, thank you for your help. I have the following tables. My goal is to populate Table A with the overall rating count of Table C for each asset in Table A. A) asset table asset_id asset_name overall_rating 1 video1 <null> 2 video2 <null> B) rating table rating_id rating 1 highest 2 high 3 neutral 4 low 5 lowest C) link_asset_to_rating (Based on how people rate the videos, the values go into this table) asset_to_ratingID asset_id rating_id 1 1 2 2 1 3 3 1 2 4 1 5 5 1 2 6 2 1 7 2 2 8 2 3 For the scenrio in Table C, I have a query that will give me the count and the max count of the values in that table (see below). So for Asset #1, the overall rating field in Table A would be 2 since '2' appeared three times in Table C and has the most ratings for that rating_id. BUT for Asset #2, there is a 3 way tie for the rating_id. How do I create a query that will compare each count of rating_id and retrieve the highest rating for that asset? So for Asset#2, I want the value '1' to be the overall rating since "highest" is the most positive response even though there was a 3 way tie. Please let me know if I need to clarify. Here is my count query that I made into a view and my max query of the count: CREATE VIEW vwCountOfRatingID AS SELECT asset_id, Count(rating_id) as CountOfRatingID, rating_id FROM link_asset_to_rating GROUP BY asset_id, rating_id SELECT Max(CountOfRatingID) FROM vwCountOfRatingID WHERE vwCountOfRatingID.asset_id=2;
I have a question: How will you determine what value '1' to be the overall rating for asset #2. from your data I can see that "Highest" is the highest rating and "neutral" is higher than "low" but how SQL Server can determine that? Can we safely assume that "lower the Rating_id is higher the rating"? If so, I believe this query will help you ;with CTE (asset_id , CountOfRatingID , Rating_id ) AS ( SELECT asset_id, Count(rating_id) as CountOfRatingID, rating_id FROM link_asset_to_rating GROUP BY asset_id, rating_id ) Select A.asset_id, a.rating_id, a.CountOfRatingID from CTE a left join CTE b on a.asset_id= b.asset_id and a.CountOfRatingID<=b.CountOfRatingID and a.Rating_id>b.Rating_id where b.Rating_id is nullPlease note that the first character of the code starts with semicolon.
Sir - Your assumption is correct that the lower the rating_id the higher the rating. I tried your query and it worked exactly as needed. You are a genius! Thank you. I will try to incorporate it into my other query but if I have any issues, I may need to ask for more assistance but for now, you got me off to a good start. Thank you again!
Can you explain to me how the query above works? I understand parts of it but do not fully understand how it works. Also, what if I wanted 5 to be the highest rating? How does that impact the query using the CTE above? Thank you!


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Download Waplog Chat & Free Dating
Waplog Chat & Free Dating
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Italian and Greek specialties in a family atmosphere. Extensive menu of fresh fish, lamb, beef, chicken, house-made pasta and ravioli, sandwiches, plus one-of-a-kind hand-tossed pizza.
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Full service bar with long wine and beer list. Special catering menu available for delivery or carry-out.
Web Development by SteadyRain Internet Strategy, Web Design, and Online Marketing


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text: Loading... Westshore (Please Select) Community Information Site Plan Driving Directions Photos Local Interests Community Brochure Home Features Finance Your Dream Sales Center: Onsite Sales Office Closed Sacramento, CA 95834 Driving Directions Print Page Sales Contact: 916-246-0759 866-477-0954 Sign Up For Updates Request Information Plan 1 Sold Out | 2,018 Sq. Ft. | 3 Bedrooms | 2 Baths | 2 Garage | 1 Story Plan 1 features 3-4 beds, 2-3 bath, a den and 2,018 square feet. Plan 1 is the only single-story plan offered at Westshore. With an extended front porch and optional covered patio in the back, there is plenty of room for outdoor living and entertaining. With an option for a bedroom or den, residents of the Plan 1 can customize this home to fit their needs. Schedule an Appointment Floor Plan 1 of 4 FLOOR PLAN PHOTOS LOCATIONS OPTIONS Personalize This Home


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Pink Moss Campion are found amongst the loose rocks on Larrabee. Mt Baker is seen on the horizon. | Mount Larrabee (Mountain/Rock) beaudaddy85's Image Gallery Gun Shots Fired, But Still A Success On Mt Larrabee & Winchester Mountain (Trip Report) Plants Of The Pacific Northwest (West) (Album) Image Data
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