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Technical Advice Memorandum 9730007 concerning periodic payments under a commodity swap In concluding that the periodic payments constituted ordinary income or expense, the IRS rejected the taxpayer s arguments that a swap was economically identical to a series of cashsettled forward contracts and that the periodic payments were made or received to close each separate forward contract The IRS concluded that, while an NPC is economically similar to a series of cash-settled forward contracts, it is a single indivisible nancial instrument Signi cantly, this Technical Advice Memorandum did not discuss the tax characterization of nonperiodic payments However, the analysis in this memorandum indicates that the IRS would also treat nonperiodic payments, or any payments made pursuant to the terms of an NPC, as ordinary income or loss.

ask the participant to group the piles into larger groups, and should probably ask for names of the piles. This is quick research with no technology investment that helps organize the features of an application. It is particularly useful for organizing a web site, but many mobile applications also have organization challenges because less information can be displayed at one time. When performing this research for a mobile application, be sure to alert the participant that the application will be delivered on a phone. For many applications this may not affect results, but the users understanding of how information is organized on a mobile phone will affect how they sort the cards for some applications. It may be worthwhile to compare sorting by users who have different device types, particularly Palm, Windows, and Symbian devices as compared to others. The higher end devices have larger screens which may affect how large the piles of cards become. Analysis of the test results is the same for mobile as it is for desktop applications, with the addition of investigating any correlation between screen size and card organization.

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When an NPC constitutes a capital asset to a taxpayer, Code section 1234A provides that a capital gain or loss results from the cancellation, lapse, expiration, or other termination of a right or obligation with respect to such asset37 Accordingly, termination payments with respect to such an NPC should constitute capital gains or losses to the recipient under this statutory provision However, there is little guidance as to whether a particular payment should be treated as a cancellation, lapse, expiration, or other termination of a right or obligation For example, should Code section 1234A apply to a contingent payment made at the maturity of an NPC (eg.

r authentication method; r allowed user or subscriber groups; r allowed access technologies; r geographical area of applicability; r handover between access technologies r r

, a payment made at the end of an equity swap that re ects price movement in the underlying equity over the term of the swap) While the IRS took the position in Technical Advice Memorandum 9730007 that Code section 1234A does not apply to payments made pursuant to the terms of an NPC, the terms of NPCs providing for contingent nal payments are factually distinguishable from the NPC analyzed in that Technical Advice Memorandum, and many tax practitioners take the position under the current rules that Code 1234A provides capital gains treatment for contingent nal payments..

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This is a slight variation of the Copy and Paste JSP AntiPattern. The consequences are a brittle Web site that is hard to change and maintain. Even if the code is in a utility class and not copied into each servlet, the Web site is still hard to maintain because the flow of the application is hard-coded into the servlet.

Sometimes it is acceptable to copy whole interrelated sets of JSPs across applications rather than attempt to properly parameterize the JSPs so they work in both contexts.

there are better means of testing available than JSPs. If you are tempted to test your back-end code with JSPs, look into Cactus. It is a JUnit derivative built specifically to test back-end J2EE code.

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