Tax Treatment of Previously Expensed Assets in Corporate Liquidations

This Note argues that although the Tennessee-Carolina majority adopts overbroad language and ignores established tax principles, a more careful refinement of its theory will yield the same proper result, without, in most situations, departing from accepted principles. The proper inquiry must focus first on whether the corporation has received any benefit, and then on whether that gain should be exempted by the nonrecognition provisions of section 336, or on any other basis. Part I of this Note examines these questions from a theoretical perspective, and concludes that expensed assets remaining at the time of liquidation give rise to corporate income, and that neither their distribution nor the liquidation of the corporation serve to dissipate the gain before it is realized. Nonrecognition treatment should not, as a matter of either rational tax policy or congressional intent, be extended to previously expensed assets. Part II focuses on the language of the Code, and offers a construction of section 336 which limits its scope to gains or losses caused by changes in the value of the assets; under this interpretation, the tax benefit conferred by the original deduction of the assets\u27 cost would be recognized as income, realized but not engendered by the liquidation. The available evidence of congressional intent fully supports this interpretation, and may independently justify the result defended by this Note. Finally, even if section 336 unequivocally bars recognition of the gain resulting from distribution of previously expensed assets, its application to previously expensed assets implicates the policies of section 111, the statutory tax benefit rule. The conflict between these sections should be resolved in favor of section 111, because denying nonrecognition to previously expensed assets does not contravene the policy purposes of section 336. Given that reasonable interpretations of the Code are consistent with the principles of rational tax policy articulated in Part I, the Note concludes that the courts should apply the tax benefit rule to previously expensed assets distributed in liquidation

Group rings: Units and their applications in self-dual codes

The initial research presented in this thesis is the structure of the unit group of the group ring Cn x D6 over a field of characteristic 3 in terms of cyclic groups, specifically U(F3t(Cn x D6)). There are numerous applications of group rings, such as topology, geometry and algebraic K-theory, but more recently in coding theory. Following the initial work on establishing the unit group of a group ring, we take a closer look at the use of group rings in algebraic coding theory in order to construct self-dual and extremal self-dual codes. Using a well established isomorphism between a group ring and a ring of matrices, we construct certain self-dual and formally self-dual codes over a finite commutative Frobenius ring. There is an interesting relationships between the Automorphism group of the code produced and the underlying group in the group ring. Building on the theory, we describe all possible group algebras that can be used to construct the well-known binary extended Golay code. The double circulant construction is a well-known technique for constructing self-dual codes; combining this with the established isomorphism previously mentioned, we demonstrate a new technique for constructing self-dual codes. New theory states that under certain conditions, these self-dual codes correspond to unitary units in group rings. Currently, using methods discussed, we construct 10 new extremal self-dual codes of length 68. In the search for new extremal self-dual codes, we establish a new technique which considers a double bordered construction. There are certain conditions where this new technique will produce self-dual codes, which are given in the theoretical results. Applying this new construction, we construct numerous new codes to verify the theoretical results; 1 new extremal self-dual code of length 64, 18 new codes of length 68 and 12 new extremal self-dual codes of length 80. Using the well established isomorphism and the common four block construction, we consider a new technique in order to construct self-dual codes of length 68. There are certain conditions, stated in the theoretical results, which allow this construction to yield self-dual codes, and some interesting links between the group ring elements and the construction. From this technique, we construct 32 new extremal self-dual codes of length 68. Lastly, we consider a unique construction as a combination of block circulant matrices and quadratic circulant matrices. Here, we provide theory surrounding this construction and conditions for full effectiveness of the method. Finally, we present the 52 new self-dual codes that result from this method; 1 new self-dual code of length 66 and 51 new self-dual codes of length 68. Note that different weight enumerators are dependant on different values of β. In addition, for codes of length 68, the weight enumerator is also defined in terms of γ, and for codes of length 80, the weight enumerator is also de ned in terms of α

Conformal Field Theories, Representations and Lattice Constructions

An account is given of the structure and representations of chiral bosonic meromorphic conformal field theories (CFT's), and, in particular, the conditions under which such a CFT may be extended by a representation to form a new theory. This general approach is illustrated by considering the untwisted and $Z_2$-twisted theories, $H(\Lambda)$ and $\tilde H(\Lambda)$ respectively, which may be constructed from a suitable even Euclidean lattice $\Lambda$. Similarly, one may construct lattices $\Lambda_C$ and $\tilde\Lambda_C$ by analogous constructions from a doubly-even binary code $C$. In the case when $C$ is self-dual, the corresponding lattices are also. Similarly, $H(\Lambda)$ and $\tilde H(\Lambda)$ are self-dual if and only if $\Lambda$ is. We show that $H(\Lambda_C)$ has a natural ``triality'' structure, which induces an isomorphism $H(\tilde\Lambda_C)\equiv\tilde H(\Lambda_C)$ and also a triality structure on $\tilde H(\tilde\Lambda_C)$. For $C$ the Golay code, $\tilde\Lambda_C$ is the Leech lattice, and the triality on $\tilde H(\tilde\Lambda_C)$ is the symmetry which extends the natural action of (an extension of) Conway's group on this theory to the Monster, so setting triality and Frenkel, Lepowsky and Meurman's construction of the natural Monster module in a more general context. The results also serve to shed some light on the classification of self-dual CFT's. We find that of the 48 theories $H(\Lambda)$ and $\tilde H(\Lambda)$ with central charge 24 that there are 39 distinct ones, and further that all 9 coincidences are accounted for by the isomorphism detailed above, induced by the existence of a doubly-even self-dual binary code.Comment: 65 page