The section 754 election of the Internal Revenue Code allows partnerships to make basis adjustments to avoid potentials for double taxation that can arise following transfers of partnership interests and distributions of partnership property. Once made, a 754 election applies to all future tax years and is revocable only with the consent of the Internal Revenue Service (Service). One subsection of the Treasury Regulations addresses when the Service might approve or deny a partnership’s request to revoke a 754 election. Despite the process contemplated in this regulation, until recently, partnerships could default out of a 754 election without Service approval through a technical termination. The lack of recorded application of the regulation implies that partnerships have largely not needed to rely on—and the Service has not needed to apply—the 754 election revocation regulation. The repeal of technical terminations under the 2017 Tax Cuts and Jobs Act, however, foreclosed the ability of partnerships to default out of a 754 election, creating not only a renewed permanence of 754 elections but also a new need for guidance concerning requests for revocation. In anticipation of both partnerships’ and the Service’s need to rely more heavily on requests for 754 election revocation, this Note provides potential factors the Service might use to consider such requests and highlights other ways partnerships might still effect a 754 election revocation without Service approval.

ABSTRACT OF THE DISSERTATION

Extended Techniques and Vocal Simulations in

Frank Ticheli's First Voice for Solo Bb Trumpet

By

Courtney Dion Jones

Doctor of Musical Arts in Trumpet Performance

University of California, Los Angeles, 2015

Professor Jens Lindemann, Chair

Unaccompanied works for trumpet that emerged during the latter half of the twentieth century (mainly since 1970) pushed the limits of technical facility well beyond what was heard in solo concerti or collaborative consorts of earlier eras and set new standards and expectations of what could be performed on the instrument. Frank Ticheli was a leader in these innovations; his compositions not only expanded the range and tonal qualities of the instrument, but also introduced more specialized techniques (such as speech simulation through vocal realizations and new modes of melodic writing involving disjunctive melodic patterns). Some of these techniques can be attributed to influences from jazz and contemporary idioms, as reflected in notational conventions familiar to jazz artists, but they also use innovative approaches to performance practice and new philosophical orientations.

The present research explores these developments through a detailed analysis of Frank Ticheli's composition The First Voice for Solo Bb Trumpet, augmented by interviews and correspondence with Ticheli himself. The intention of this research is to broaden the technical capabilities of 21st century performers, as well as shed light on the ideological and philosophical concepts on which the aforementioned developments are based. From a musicological perspective, this dissertation is primarily analytic and interpretive. However, it is hoped that trumpet players who use it for its pedagogical value will develop an increased confidence in performing The First Voice for Solo Bb Trumpet and other contemporary compositions in related genres.

Recent studies in genomics have highlighted the significance of structural variation in deter-

mining individual variation. Current methods, however, are predominantly focused on either

assembling whole genomes from scratch, or identifying the relatively small changes between

a genome and a reference sequence. While significant progress has been made in recent years

on both de novo assembly and resequencing (read mapping) methods, few attempts have

been made to bridge the gap between them.

In this paper, we present a computational method for incorporating a reference sequence

into an assembly algorithm. We propose a novel graph construction that builds upon the

well-known de Bruijn graph to incorporate the reference, and describe a simple algorithm,

based on iterative message passing, which uses this information to significantly improve

assembly results. We validate our method by applying it to a series of 5Mb simulation

genomes derived from both mammalian and bacterial references. The results of applying

our method to this simulation data are presented along with a discussion of the benefits and

drawbacks of this technique.

In The Burial at Thebes, King Creon uses the metaphor "ship of state" to describe his kingdom. He emphasizes the importance of focusing on the community of Thebes instead of the desires of individuals, just like a group of sailors must prioritize arriving at their destination without overly identifying with the needs of the rest of the crew. I have learned that the theatrical production process can be compared to the running of a ship, including a group of sailors, or collaborators, working toward a common goal. As the Production Stage Manager of Thebes, I played an important part in navigating the ship towards the goal of a fully realized production. Much like Creon states at his inauguration about making choices "in the interest of all citizens," I was challenged to act instead of react and intentionally focus on the big picture.

During my graduate studies, I have been challenged to sustain an embodied presence when triggered by production challenges. I have learned multiple tools to assist in refocusing my energy to the demands of the overall production. My ability to remain present, without judgment, to the needs of all collaborators, has empowered me to make wiser choices. This insight has provided me with an awareness and heightened clarity that will be vital in future endeavors, and the knowledge that subtle choices have a significant impact on the production process. In moving forward, I plan to continue build upon this strength of awareness as I embark on my next voyage.

Urban ecosystems are defined by unique relationships between biological diversity and distribution, socio-demographics, and climate. These relationships occur in the context of a changing world: increasing temperatures, a shifting composition of urban residents, and rapid urbanization. It is likely that the relationships which structure the urban environment, such as that between temperature and income, or race-based exposure to heat and greenness, are not temporally stable. As urban temperatures and greenness have well known associations with morbidity, mortality, and mental health, non-stationarity of urban ecological relationships may pose significant challenges to the well-being of urban residents. I tested assumptions about non-stationarity by assessing the change through time of urban ecological relationships at three distinct spatial scales: the urban (single city) scale (chapter 1), at a continental scale (chapter 2), and at a global scale (chapter 3). At each spatial scale I used a multidecadal time series of satellite imagery, coupled with landcover and socio-demographic information, to assess how the dynamics of urban greenness, temperature, and vegetative cooling evolved through time and what factors mediated any change. In chapter 1, where I used Los Angeles, CA as a case study, I found large intra-urban variability in how greenness, temperature, and vegetative cooling changed over time. The consequence of these changes was a weakening of the effectiveness of income as a mediator of urban greenness and temperature (the luxury effect). I corroborated the multidecadal decline in the luxury effect in chapter 2, a continental-scale assessment where I looked at 52 cities from the conterminous United States. In this chapter I additionally compared the biophysical dynamics in every city with a nearby non-urban reference site. Urbanization weakened the relationship between the weather and landcover and the biophysical environment, where the most arid cities were entirely decoupled from precipitation. In chapter 3, I looked at a subset of 266 global cities from 82 countries, finding that the evolving relationship between greenness and temperature led to declines in the cooling effectiveness of urban vegetation. Overall, this dissertation highlights the non-stationarity of urban dynamics, as well as the importance of climatic context in understanding these urban relationships.