A Conceptual Framework for Capital Gain

Qualification for preferential tax rates on capital gain is “fuzzy at best and incoherent at worst.” The primary governing statute provides that sale or exchange of “property” yields capital gain, with only narrow exceptions. Under traditional understanding, however, capital gain does not include income, including rent, interest, compensation, and periodic business income, even though such income is received on the sale of something reasonably considered to be “property” in nontax contexts. A conceptual framework is needed that brings both courts and congressional rules into consistency and produces principled results; this Article presents such a framework. The proposed framework assumes that the capital gain preference will remain. It draws its principles from the wisdom of current law but then criticizes some judicial and congressional results as anomalies inconsistent with those principles. The framework is organized into five strings, with each string representing a separate rationale. The Article then briefly explores three situations where there would no room for a capital gains preference: under a consumption tax, under a mark-to-market system, and under repeal of step up in basis at death

Resilience Assignment Framework using System Dynamics and Fuzzy Logic.

This paper is concerned with the development of a conceptual framework that measures the resilience of the transport network under climate change related events. However, the conceptual framework could be adapted and quantified to suit each disruption’s unique impacts. The proposed resilience framework evaluates the changes in transport network performance in multi-stage processes; pre, during and after the disruption. The framework will be of use to decision makers in understanding the dynamic nature of resilience under various events. Furthermore, it could be used as an evaluation tool to gauge transport network performance and highlight weaknesses in the network. In this paper, the system dynamics approach and fuzzy logic theory are integrated and employed to study three characteristics of network resilience. The proposed methodology has been selected to overcome two dominant problems in transport modelling, namely complexity and uncertainty. The system dynamics approach is intended to overcome the double counting effect of extreme events on various resilience characteristics because of its ability to model the feedback process and time delay. On the other hand, fuzzy logic is used to model the relationships among different variables that are difficult to express in numerical form such as redundancy and mobility

The evaluation of E-business related technologies in the Railway Industry

For the purposes of this paper, e-business is defined as: "the performance, automisation and organisation of transactions, or chains of them, and the gathering and publishing of data, electronically over a communication protocol" Little research has been conducted either into how e-business technology can be successfully evaluated, or into the associated costs and benefits specifically related to the transportation and railway industries. Based upon a review of the current literature and a series of interviews held with railway operators, track managers and transportation customers from the Australian Fortune 100, the paper puts forward a framework for the evaluation of e-business investments within the railway industry. The research reported here is aimed at developing a flexible interface that enables the decision maker to assess and evaluate a wide variety of complex interacting variables. The proposed approach uses a variety of evaluation methods, as opposed to searching for a single "best" approach. Additionally, an attempt is being made to include the complex interaction between the implementation of the new technology and the changing organisational setting. A model is proposed using fuzzy logic to handle incomplete and uncertain knowledge; as well as to combine criteria within a conceptual model from which "real-worth" evaluations can be performed. This model provides a systematic approach to guide the decision maker in the deployment of e-business and emerging technologies in the industry. After discussing the main findings from a literature review on the use of evaluation frameworks in IT related projects, the paper deals with the proposed framework in detail. The use of empirical data, which was obtained transportation customers to help define the main framework factors, is also discussed. Finally, the paper summarises the main implications for rail freight of customers’s perceptions and stated needs in the e-business domain

Cognitive visual tracking and camera control

Cognitive visual tracking is the process of observing and understanding the behaviour of a moving person. This paper presents an efficient solution to extract, in real-time, high-level information from an observed scene, and generate the most appropriate commands for a set of pan-tilt-zoom (PTZ) cameras in a surveillance scenario. Such a high-level feedback control loop, which is the main novelty of our work, will serve to reduce uncertainties in the observed scene and to maximize the amount of information extracted from it. It is implemented with a distributed camera system using SQL tables as virtual communication channels, and Situation Graph Trees for knowledge representation, inference and high-level camera control. A set of experiments in a surveillance scenario show the effectiveness of our approach and its potential for real applications of cognitive vision

A framework for Thinking about Distributed Cognition

As is often the case when scientific or engineering fields emerge, new concepts are forged or old ones are adapted. When this happens, various arguments rage over what ultimately turns out to be conceptual misunderstandings. At that critical time, there is a need for an explicit reflection on the meaning of the concepts that define the field. In this position paper, we aim to provide a reasoned framework in which to think about various issues in the field of distributed cognition. We argue that both relevant concepts, distribution and cognition, must be understood as continuous. As it is used in the context of distributed cognition, the concept of distribution is essentially fuzzy, and we will link it to the notion of emergence of system-level properties. The concept of cognition must also be seen as fuzzy, but for different a reason: due its origin as an anthropocentric concept, no one has a clear handle on its meaning in a distributed setting. As the proposed framework forms a space, we then explore its geography and (re)visit famous landmarks

Simulation of complex environments:the Fuzzy Cognitive Agent

The world is becoming increasingly competitive by the action of liberalised national and global markets. In parallel these markets have become increasingly complex making it difficult for participants to optimise their trading actions. In response, many differing computer simulation techniques have been investigated to develop either a deeper understanding of these evolving markets or to create effective system support tools. In this paper we report our efforts to develop a novel simulation platform using fuzzy cognitive agents (FCA). Our approach encapsulates fuzzy cognitive maps (FCM) generated on the Matlab Simulink platform within commercially available agent software. We firstly present our implementation of Matlab Simulink FCMs and then show how such FCMs can be integrated within a conceptual FCA architecture. Finally we report on our efforts to realise an FCA by the integration of a Matlab Simulink based FCM with the Jack Intelligent Agent Toolkit