The step transaction doctrine is one of the judicial doctrines used by the courts to interpret tax law. The doctrine requires that a series of transactions be treated as a single transaction if the transactions share a single, integrated purpose. Many authors believe there is a great deal of uncertainty as to when the doctrine will be applied. Uncertainty and inconsistency in the application of tax law add to the complexity of the law. One of the most complex areas of tax law is Subchapter C of the Internal Revenue Code, which governs corporate formations, redemptions, liquidations, distributions, and reorganizations. The purpose of this study was to determine if the step transaction doctrine is being consistently applied by the Tax Court and what variables affect the judges' decision in these cases. Hierarchical logit analysis was used to derive a full model and two restricted models. The full model was used to determine the predictive power of the variables that were identified and to explain the extent to which the individual variables affect the judges' decisions. One restricted model was used to test temporal stability. The other was used to test consistency when different issues of tax law are involved. The …

The objective of this research is the investigation of the patterns of information growth to test whether there has been an "information explosion." To tackle the main problem, there are three issues which need to be addressed: (1) the concept of information dimensionality; (2) determination of common parameters to measure the amount of information within each dimension; and (3) a working definition of "explosiveness. "

One perceived deficiency in the tax system is its unfairness (inequity). One area in which unfairness has been alleged is the favoritism shown toward homeowners. The focus of this study was on the effects of homeowner preferences on the Federal tax system. The overall impact of homeowner preferences can be said to produce three major results—loss of revenue, reduction in horizontal equity, and reduction in vertical equity.

This study is designed to evaluate the impact of citizen participation in the Goals for Dallas program on the establishment and accomplishment of the goals. Also evaluated are the impact of community leaders on the program, the extent and degree of citizen participation, factors which encouraged and discouraged participation, the impact of local media, and the impact on citizen participants of participating. Twenty-five specific findings are presented, based on the compilation and analysis of inputs received from the citizens and community leaders. Among the most important of these are as follows. 1) The extent of participation on the part of those citizens who did participate in the program was significant. 2) Related to the total adult population of the city, the extent of total citizen participation was small. 3) The program as designed and implemented did have a substantial impact in assisting to overcome citizen apathy in the city. 4) The key items which tended to encourage citizen participation were publicity, civic duty, neighborhood meetings, and personal rewards. 5) The general factors which discouraged citizen participation were general suspicion of the program, general apathy, lack of publicity, and a general suspicion of government. 6) Citizen participation had a significant impact …

The area of performance appraisal of the handicapped individual is a relatively uncharted domain. Previous studies have tended to either lump categories of handicaps together or to concentrate their performance appraisal on simplistic performance criteria. This dissertation focused upon the performance of a group of physically impaired workers and their non-impaired co-workers. Central to this research endeavor was a comparison of the aggregate performances of both groups of workers through the use of parametric factor and discriminant techniques as well as the non-parametric sign test.

This study tested the existence of significant differences in levels of perceived job stressors between non-managerial individuals in boundary-spanning and nonboundary- spanning occupations. Correlations between selected demographic characteristics and levels of perceived job stressors were also determined.

This dissertation examines the role of the fundamental economic variables (price levels, interest rates, and income levels) in the determination of foreign exchange rates during the period 1973-1978. Purchasing power parity, the International Fisher Effect, and the relationship of exchange rates with income levels through the marginal propensity to import were integrated, as suggested by the literature, and a fairly reasonable specification of a model for exchange rate determination was measured. The results of speculation tests indicate destabilizing results for some currencies and stabilizing results for the others; the coefficient of expectation tests, however, lend support to the destabilizing hypothesis. The conclusion of the research, therefore, is that the exchange rates of the major industrial countries which are of prime importance to the international financier and investor, and to the student of international finance and trade, are primarily determined, not by the fundamental economic variables, but by speculative forces which are believed to be of a destabilizing nature.

Private philanthropy is important in America. In 1985, philanthropy totaled almost 80 billion dollars. Philanthropy is partially a function of price. Absent a tax benefit, the price of charitable giving is unity. When tax benefits are available, the price of cash giving is one minus the marginal tax rate of the donor. Philanthropy is not evenly distributed among all classes of organizations. Changes in tax cost bring about changes in the distribution of gifts among organizations. Predictions have been made of a six to twelve billion dollar decline in individual giving as a result of the Tax Reform Act of 1986. The question is, "Whose ox gets gored?" In 1962, the Internal Revenue Service collected data directly linking itemized charitable contributions to class of donee organization. Prior works by Taussig, Schwartz, Feldstein, and Clotfelter have been principally based on this data. Their works document differing elasticities of price on charitable giving. The current research gathered 1985 data on the relationships between income, price, and charitable donee for 298 Dallas County, Texas, taxpayers. Data was obtained from selected certified public accountants in Dallas County who prepared income tax returns for individuals as part of their practice. Two hundred fifty usable responses …

The purpose of this study was to examine the effectiveness of the Civil Service Reform Act of 1978 on the federal civil service through the establishment of the Merit Systems Protection Board. The Civil Service Reform Act of 1978 was designed to correct many of the abuses which existed under the Civil Service Commission related to appeals procedures and inefficiency within the federal government. The majority of data collected for this study were obtained from the Dallas field office of the Merit Systems Protection Board, which covers approximately 275,000 federal employees in a five-state area. Additional data, related to all of the regional field offices of the Merit Systems Protection Board, were obtained from Washington, D.C. Two research tools were used to collect data from the Dallas field office: a questionnaire and a personal interview. Three hypotheses were examined. Hypothesis I stated that the creation of the Merit Systems Protection Board has not given presiding officials any additional authority to handle or decide adverse action cases brought within their jurisdiction. Hypothesis II stated that the length of time needed to process adverse action cases has not decreased since the creation of the Merit Systems Protection Board. Hypothesis III stated that …

In recent years, considerable interest has been stimulated concerning potential conflicts of interest between a company's management and their independent auditors. Many researchers examined the association between corporations who changed their present auditors, and factors such as auditor's opinion on the financial statements, management changes, mergers, financial distress, etc. Some of these research efforts resulted in findings that were inconsistent with each other. The current research was therefore undertaken with the objective of developing a theoretical model of auditor change process and to explain the justification for considering certain specific factors that may be present in an auditor-client relationship. The research design and the methodology for analyses were developed on the basis of the theory on power conflicts found in political science literature and by the use of Wrong's power model on authority relationship. Sources of power such as the size of an audit firm, size of a corporation, the stock exchange membership, the ability of an auditor to qualify the opinion on the financial statements, the ability of the management of a corporation to terminate the audit contract following the issue of a qualified opinion, and change of a corporation's CEO were identified and converted into independent variables. Data …

The purpose of this research is to study and improve decision accuracy in the real world. Spot price prediction of petroleum products, in a budgeting context, is the task chosen to study prediction accuracy. Prediction accuracy of executives in a multinational oil company is examined. The Brunswik Lens Model framework is used to evaluate prediction accuracy. Predictions of the individuals, the composite group (mathematical average of the individuals), the interacting group, and the environmental model were compared. Predictions of the individuals were obtained through a laboratory experiment in which experts were used as subjects. The subjects were required to make spot price predictions for two petroleum products. Eight predictor variables that were actually used by the subjects in real-world predictions were elicited through an interview process. Data for a 15 month period were used to construct 31 cases for each of the two products. Prediction accuracy was evaluated by comparing predictions with the actual spot prices. Predictions of the composite group were obtained by averaging the predictions of the individuals. Interacting group predictions were obtained ex post from the company's records. The study found the interacting group to be the least accurate. The implication of this finding is that even …

Why do employees vote for or against union representation? A survey of the scholarly literature and an investigation of National Labor Relations Board sponsored elections among Southern industrial workers were conducted to help answer this question. Four hypotheses were proposed to reveal the most important factors. No universally applicable laws were developed by the dissertation study. Although the hypotheses were supported, the response rate was very low in the field research study of sensitive issues. The field research did provide additional empirical evidence to support most of the previous research studies concerning union representation election voting behavior.

A non-experimental, descriptive study was conducted to examine the criteria by which ad hoc labor arbitrators are selected in the petroleum refining industry. Three factors — arbitrator background, recognition, and arbitration practice — were examined to determine their relative importance to advocates selecting ad hoc labor arbitrators. The population of the study consisted of management and labor union advocates in the petroleum refining industry who routinely select ad hoc labor arbitrators. Participating management and union advocates completed a questionnaire used to gather respondents' evaluations of criteria considered in the selection of ad hoc arbitrators. Responses to statements designed for measuring relative importance of the criteria considered were recorded. Descriptive statistics, discriminant analysis, and tests of significance were used in the treatment of the data.

Much has been written during the past decade to explain the relationship between financial and operating leverage and stock-price volatility. However, the relationship between combined leverage and stock-price volatility has yet to be fully explored. Mandelker and Rhee's (MR) recent study uses both operating and financial leverage in a regression (equivalent to the traditional total leverage—DTL) and shows that both types of leverage are positively associated with common stock betas. Huffman recently demonstrated that there are interactions between operating leverage and financial leverage. Therefore, MR's model could be oversimplified. This study examines the relationship between firms' combined leverage and their stock-price volatility. The study also examines industry and industry growth to see if the relationship is influenced by these factors. The question is whether DOCL is a better risk measure than DTL and whether there is an interaction between operating and financial leverage. The inferences that can be drawn from the study's results are as follows: (a) Stock risk is a function of combined leverage; (b) Industry significantly influences the relationship between stock risk and DOCL; (c) High growth increases the relationship between stock risk and DOCL; (d) Combined leverage (DOCL) is a better risk measure than total leverage (DTL). …

The purpose of the research was to test Walker's assertion that the human resource planning process of an organization is influenced by selected organizational characteristics, and to investigate Walker s typology for implementing and evaluating human resource planning systems. Chapter I introduces the research topic and provides a justification for the study. Chapter II describes the methodology and presents the findings. Chapter III analyzes the findings. The final chapter summarizes the findings and offers conclusions drawn from the research.

This study is intended, first, to describe and analyze the channels of distribution for food products in the State of Kuwait, second, to pinpoint the problems that exist in the food-distribution system, and, third, to make specific recommendations for the alleviation of the problems. Consistent with the objectives of the study and based on the description and analysis of the food-distribution system in the country, it is concluded in the study that Kuwait depends on imports for virtually all of its food; the government plays a major role in the food-distribution system; and the majority of food wholesaling and retailing establishments are small, inefficient, and lack modern marketing and physical distribution techniques. Product shortages and rising food prices plague the food-distribution system in the country. Also, the findings indicate that consumers in Kuwait are generally ignorant and uninformed in the areas of food nutrition and food shopping, and the lack of standardization and grading of food products makes the shopping task of the consumer more difficult.

Catastrophe theory (CT) is a relatively new mathematical theory that comprehensively describes a system exhibiting discontinuous behavior when subjected to continuous stimuli. This study tests the theory using capital-market data. The data is a time series of stock returns on firms that filed for Chapter 11 reorganization during 1980-1985. The CT model used is based on a corporate failure model suggested by Francis, Hastings and Fabozzi (1983). The model predicts 1) as the filing date approaches, there will be a structural shift in the underlying stock-return generating process of the filing firm, and 2) firms with lower operating risk will have a smaller jump than firms with higher operating risk, corresponding to their relative positions within the bifurcation set of the catastrophe cusp.

The problem of this investigation was to make an exploratory examination of the distribution practices of apparel manufacturers as perceived by apparel retailers. Specifically, the purposes of this study were to identify those areas of perceived conflict between women's apparel retailers and apparel manufacturers from the viewpoint of the retailer, determine if there was a relationship between select retailer variables and the quality of service that retailers perceived apparel manufacturers were giving, determine whether some merchandise classifications were perceived by retailers to be greater problem areas than other merchandise classifications, to determine factors contributing to the enhancement of perceived conflict within apparel marketing channels, and to suggest remedies that would improve apparel channel relationships. The report concluded with the presentation of an apparel retailer expectation model and suggestions for additional research.

The purpose of this study is twofold. First, the results of the study are used to isolate the impact of ESOP financing on actual firms as closely as possible. This is simply to point out many of the advantages and disadvantages of ESOP financing. Second, the results of the study are used to compare the relative costs of ESOP's with other deferred employee compensation. In general, the findings indicate that ESOP's have little to offer as a means of financing for publicly held corporations, However, they may have certain advantages when used as a part of a firm's total employee compensation package. The findings indicate that accounting rules for certain types of ESOP's tend to distort per share calculation in the early years of the plan. To correct this, ESOP shares should be considered outstanding only as they become unencumbered. The study found that a definite need exists for empirical data relating to ESOP's motivational effects. This is a key factor in determining how the ESOP will affect a firm's financial structure. Further study of this aspect would provide valuable information regarding the ESOP's effect on the firm's productivity.

In this study, the possibility that money demand of one country might be affected by macroeconomic activities of other countries is investigated. We use the seemingly unrelated regression (SUR) technique, which takes into account all covariances between residuals of country-specific money demand equations. Efficiency of estimates using the SUR technique is enhanced because it uses information contained in the contemporaneous correlation of the error terms. The hypothesis of economic interdependence is tested. A proxy for foreign influence, deviation from interest rate parity (DIRP), is tested for significance in the money demand function.

This study examined a segment of the homeless population who participated in a jobs training program. The research investigated the effect of socioeconomic status, self-esteem, and locus of control on the clients in getting and keeping jobs. The training was a comprehensive 36-day treatment dealing with three major areas: (a) how to get a job, (b) how to keep a job, and (c) how to develop life-coping skills. A quasi-experimental research design was used for testing by t-tests, two-by-two repeated-measured anova, chi-square tests, and regression analysis. The findings showed that high socioeconomic status clients demonstrated higher self-esteem and internal locus of control than low socioeconomic status clients at the start of the treatment. The treatment had a significant effect on both groups with an increase in self-esteem and internal locus of control and a decrease in both external locus of control dimensions of powerful others and chance. The treatment had a greater effect on the low socioeconomic status clients than on the high socioeconomic status clients on increases in self-esteem and locus of control—internal. Both groups were successful in finding jobs, with 79% for high socioeconomic status clients and 74% for low socioeconomic status clients having jobs at the end …

The correlates of organizational communication to other organizational constructs have been scarcely researched. Two constructs of interest to management researchers and practitioners are job performance and job satisfaction. This interest arises from the fact that the quality of organizational life and effectiveness may be determined by the quality of the two constructs. This study investigates the moderating influence of organizational communication on two models involving the variables of performance and satisfaction: (1) the relationship between performance and satisfaction and (2) the relationship between the congruence of the individual and the job with performance and satisfaction. Organizational communication is assessed in terms of ten dimensions: trust in superiors; influence of superiors; accuracy of information; desire for interaction; communication satisfaction; overload and underload information; and upward, downward, and lateral communication. Executives, research and middle management people, office workers, and manufacturing individuals from two firms provided the data for the study. An expected moderating influence was evaluated through differential validity or differential predictability, as appropriate, and moderated regression analysis. Organizational communication received very weak support as a moderator of both the relationship between the target variables of performance and satisfaction and the individual-job congruence association with the same target variables. Accuracy of information, …

The purpose of this study was to analyze the developing organizational and management paradigms in the aluminum packaging and container industry, where reverse channels of distribution offer an excellent vehicle for studying organizations which are "closing the distribution circle." Based on the analysis, several conclusions are offered. 1. The extent to which primary manufacturers have entered aluminum packaging and container recycling and subsequently developed effective reverse channels of distribution is contingent upon needs for resources. 2. The most successful recycling programs are those which have decentralized organizations. 3. Central to beverage producers' decisions to develop extensive reverse channels of distribution is the belief that recycling is (1) a deterrent to container legislation, (2) a source of favorable publicity, (3) a source of company profits, and (4) can improve supply relationships with primary aluminum suppliers. 4. Regional beverage companies in the environmentally conscious Far West have the most successful and comprehensive recycling operations. 5. Loose organizational federations such as those of the soft drink franchise do not seem amenable to the development of reverse channels of distribution. 6. Where i t serves the needs of the enterprise, firms are developing sophisticated and efficient reverse channels of distribution. The institution of reverse …

This study examines the usefulness of general price level information (GPL) and current cost information (CC) originally provided by SFAS No. 33 as compared to historical cost information (HC) in predicting bankruptcy. The study also examines the usefulness of GPL data versus CC data when each supplements HC data. In addition, this study tests the usefulness of the three types of information systems combined in one model (HC, GPL, and CC) versus HC data in predicting bankruptcy. The study focuses on the predictability of business failure using financial ratios as predictors. A comparison of these predictors is made in order to identify the accounting system that yields a better prediction of bankruptcy. Two multivariate statistical techniques, multiple discriminant analysis (MDA) and logistic regression analysis (LRA), are used to derive the ex—post classification and the ex-ante prediction results. Six functions are developed, based on ratios computed with HC, CC, GPL, the combined HC and GPL, the combined HC and CC, and the combined HC, GPL, and CC. The resulting functions are used to classify 40 firms as failed or nonfailed. The analysis is repeated for three time bases—one, two, and three years before bankruptcy. The main results of the various analyses …