5,057 research outputs found

    ADMINISTRATIVE LAW - TAXATION - POWER OF BOARD TO ADOPT RULES AND REGULATIONS - INFLEXIBILITY OF PRIOR RULING BY REENACTMENT OF STATUTE WITHOUT CHANGE

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    The respondent oil company in computing its net income for the years 1929-1930 for the purpose of applying the depletion deduction provisions of the Revenue Act of 1928 refused to deduct certain development expenditures, although it had deducted those development expenditures in computing its taxable net income for these years. Under the rule-making power of section 23 (1) of that act, the commissioner defined net income of the taxpayer as used in section 114 (b)(3) as meaning gross income from the sale of gas and oil less certain deductions, including development expenses (if the taxpayer had elected to deduct development expenses rather than charging them to capital account returnable through depletion). The depletion provision of the Revenue Act of 1928 was substantially the same as the 1921 Act, the 1924 Act, and the 1926 Act. Under the Acts of 1921 and 1924, the admitted Treasury practice was to permit net income from the property for the purposes of depletion to be computed without regard to development expenditures, that practice being embodied in a ruling under the Act of 1924. In a controversy to determine whether respondent was compelled to deduct development expenses to reach net income for the purposes of depletion, the Board of Tax Appeals held for respondent deciding that the prior Treasury ruling had received judicial sanction under the 1926 Act and had been adopted by Congress by the reenactment of the same provision in the 1928 Act. The decision was affirmed by the United States Circuit Court of Appeals, one judge dissenting, upon the theory that Congress by repeated reenactment of the provision adopted the prior ruling as the proper expression of legislative intent. The Supreme Court reversed and held for the commissioner, deciding that the rule of statutory construction contended for is not so inflexible as to preclude a change of interpretation through the exercise of rule-making power. Helvering v. Wilshire Oil Co., (U. S. 1939) 60 S. Ct. 18

    Observations of Binary Stars with the Differential Speckle Survey Instrument. II. Hipparcos Stars Observed in 2010 January and June

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    The results of 497 speckle observations of Hipparcos stars and selected other targets are presented. Of these, 367 were resolved into components and 130 were unresolved. The data were obtained using the Differential Speckle Survey Instrument at the WIYN 3.5 m Telescope. (The WIYN Observatory is a joint facility of the University of Wisconsin-Madison, Indiana University, Yale University, and the National Optical Astronomy Observatories.) Since the first paper in this series, the instrument has been upgraded so that it now uses two electron-multiplying CCD cameras. The measurement precision obtained when comparing to ephemeris positions of binaries with very well known orbits is approximately 1-2 mas in separation and better than 0°.6 in position angle. Differential photometry is found to be in very good agreement with Hipparcos measures in cases where the comparison is most relevant. We derive preliminary orbits for two systems

    A Study of Out-of-turn Interaction in Menu-based, IVR, Voicemail Systems

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    We present the first user study of out-of-turn interaction in menu-based, interactive voice-response systems. Out-ofturn interaction is a technique which empowers the user (unable to respond to the current prompt) to take the conversational initiative by supplying information that is currently unsolicited, but expected later in the dialog. The technique permits the user to circumvent any flows of navigation hardwired into the design and navigate the menus in a manner which reflects their model of the task. We conducted a laboratory experiment to measure the effect of the use of outof- turn interaction on user performance and preference in a menu-based, voice interface to voicemail. Specifically, we compared two interfaces with the exact same hierarchical menu design: one with the capability of accepting out-ofturn utterances and one without this feature. The results indicate that out-of-turn interaction significantly reduces task completion time, improves usability, and is preferred to the baseline. This research studies an unexplored dimension of the design space for automated telephone services, namely the nature of user-addressable input (utterance) supplied (in-turn vs. out-of-turn), in contrast to more traditional dimensions such as input modality (touch-tone vs. text vs. voice) and style of interaction (menu-based vs. natural language)

    America\u27s Weather Warriors, 1814-1985

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    Evolution of an ancient protein function involved in organized multicellularity in animals.

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    To form and maintain organized tissues, multicellular organisms orient their mitotic spindles relative to neighboring cells. A molecular complex scaffolded by the GK protein-interaction domain (GKPID) mediates spindle orientation in diverse animal taxa by linking microtubule motor proteins to a marker protein on the cell cortex localized by external cues. Here we illuminate how this complex evolved and commandeered control of spindle orientation from a more ancient mechanism. The complex was assembled through a series of molecular exploitation events, one of which - the evolution of GKPID's capacity to bind the cortical marker protein - can be recapitulated by reintroducing a single historical substitution into the reconstructed ancestral GKPID. This change revealed and repurposed an ancient molecular surface that previously had a radically different function. We show how the physical simplicity of this binding interface enabled the evolution of a new protein function now essential to the biological complexity of many animals
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