Federal Tax Rulings: Procedure and Policy

The rulings program of the Internal Revenue Service was designed to meet the need for predictability of the tax consequences of any given financial transaction. Though the rulings program is not particularly important to the average taxpayer, it has become increasingly crucial both to the financial community and to the Service itself. As the tax laws become more complex, and tax risks become increasingly important to the success of business ventures, the need for confirmation before entering into a transaction is intensified. Thus parties to a transaction will generally request a ruling... whenever the answer is uncertain or when the transaction involves substantial sums of money, even when the uncertainty may not be very great. In such circumstances the availability of a ruling in advance of the transaction has become almost as important as the financing or the know-how involved. This note will study the growth of the rulings program, the factors which must be weighed by the tax practitioner before requesting a ruling, and the amount of reliance which the taxpayer can safely place upon the Service\u27s interpretation of the law as applied to his particular fact situation

A Comparative Investigation of Grading Systems in High School Bands

It was the purpose of this study to (1) ascertain the major types of grading systems being used in high school band classes, (2) to explore the strong and weak points of these systems, and (3) to determine which system of grading provides the most satisfactory means of evaluating and reporting the individual band member\u27s activities in the high school band

Techniques for measuring atmospheric aerosols at the High Resolution Fly's Eye experiment

We describe several techniques developed by the High Resolution Fly's Eye experiment for measuring aerosol vertical optical depth, aerosol horizontal attenuation length, and aerosol phase function. The techniques are based on measurements of side-scattered light generated by a steerable ultraviolet laser and collected by an optical detector designed to measure fluorescence light from cosmic-ray air showers. We also present a technique to cross-check the aerosol optical depth measurement using air showers observed in stereo. These methods can be used by future air fluorescence experiments.Comment: Accepted for publication in Astroparticle Physics Journal 16 pages, 9 figure

Reduction of salt in yeasted wheat bread: impact on bread quality and solutions using sourdough fermented by functional lactic acid bacteria strains

The dietary intake of sodium chloride has increased considerably over the last few decades due to changes in the human diet. This higher intake has been linked to a number of diseases including hypertension and other cardiovascular diseases. Numerous international health agencies, as well as the food industry, have now recommended a salt intake level of 5-6 g daily, approximately half of the average current daily intake level. Cereal products, and in particular bread, are a major source of salt in the Western diet. Therefore, any reduction in the level of salt in bread could have a major impact on global health. However, salt is a critical ingredient in bread production, and its reduction can have a deleterious effect on the production process as well as on the final bread quality characteristics such as shelf-life, bread volume and sensory characteristics, all deviating from the bakers’ and consumers’ expectations. This work addresses the feasibility of NaCl reduction in wheat bread focusing on options to compensate NaCl with the use of functional sourdoughs. Three strains were used for the application of low-salt bread; L. amylovorus DSM19280, W. cibaria MG1 and L. reuteri FF2hh2. The multifunctional strain L. reuteri FF2hh2 was tested the first time and its application could be demonstrated successfully. The functionalities were based on the production of exopolysaccharides as well as the production of antifungal compounds. While the exopolysaccharides, mainly high molecular dextrans, positively influenced mainly bread loaf volume, crumb structure and staling rate, the strains producing antifungal compounds prolonged the microbial shelf life significantly and compensated the lack of salt. The impact on the sensory characteristics of bread were evaluated by descriptive sensory evaluation. The increase in surface area as well as the presence of organic acids impacted significantly on the flavour profile of the sourdough bread samples. The flavour attribute “salt” could be enhanced by sourdough addition and increased the salty perception. Furthermore, a trained sensory panel evaluated for the first time the impact of yeast activity, based on different salt and yeast concentrations, on the volatile aroma profile of bread crumb samples. The analytical measurements using high resolution gas chromatography and proton-transfer-reaction mass spectrometry (PTR-MS) resulted in significantly different results based on different yeast activities. Nevertheless, the extent of the result could not be recognised by the sensory panel analysing the odour profile of the bread crumb samples. Hence, the consumer cannot recognised low-salt bread by its odour. The use of sourdough is a natural option to overcome the broad range of technological issues caused by salt reduction and also a more popular alternative compared to existing chemical salt replacers

Next generation software environments : principles, problems, and research directions

The past decade has seen a burgeoning of research and development in software environments. Conferences have been devoted to the topic of practical environments, journal papers produced, and commercial systems sold. Given all the activity, one might expect a great deal of consensus on issues, approaches, and techniques. This is not the case, however. Indeed, the term "environment" is still used in a variety of conflicting ways. Nevertheless substantial progress has been made and we are at least nearing consensus on many critical issues.The purpose of this paper is to characterize environments, describe several important principles that have emerged in the last decade or so, note current open problems, and describe some approaches to these problems, with particular emphasis on the activities of one large-scale research program, the Arcadia project. Consideration is also given to two related topics: empirical evaluation and technology transition. That is, how can environments and their constituents be evaluated, and how can new developments be moved effectively into the production sector

Momentum Transfer Dependence of Nuclear Transparency from the Quasielastic ^(12)C(e, e'p) Reaction

The cross section for quasielastic ^(12)C(e,e’p) scattering has been measured at momentum transfer Q^2=1, 3, 5, and 6.8 (GeV/c)^2. The results are consistent with scattering from a single nucleon as the dominant process. The nuclear transparency is obtained and compared with theoretical calculations that incorporate color transparency effects. No significant rise of the transparency with Q^2 is observed

Air fluorescence measurements in the spectral range 300-420 nm using a 28.5 GeV electron beam

Measurements are reported of the yield and spectrum of fluorescence, excited by a 28.5 GeV electron beam, in air at a range of pressures of interest to ultra-high energy cosmic ray detectors. The wavelength range was 300 - 420 nm. System calibration has been performed using Rayleigh scattering of a nitrogen laser beam. In atmospheric pressure dry air at 304 K the yield is 20.8 +/- 1.6 photons per MeV.Comment: 29 pages, 10 figures. Submitted to Astroparticle Physic

Multiple Dendritic Cell Populations Activate CD4+ T Cells after Viral Stimulation

Dendritic cells (DC) are a heterogeneous cell population that bridge the innate and adaptive immune systems. CD8α DC play a prominent, and sometimes exclusive, role in driving amplification of CD8+ T cells during a viral infection. Whether this reliance on a single subset of DC also applies for CD4+ T cell activation is unknown. We used a direct ex vivo antigen presentation assay to probe the capacity of flow cytometrically purified DC populations to drive amplification of CD4+ and CD8+ T cells following infection with influenza virus by different routes. This study examined the contributions of non-CD8α DC populations in the amplification of CD8+ and CD4+ T cells in cutaneous and systemic influenza viral infections. We confirmed that in vivo, effective immune responses for CD8+ T cells are dominated by presentation of antigen by CD8α DC but can involve non-CD8α DC. In contrast, CD4+ T cell responses relied more heavily on the contributions of dermal DC migrating from peripheral lymphoid tissues following cutaneous infection, and CD4 DC in the spleen after systemic infection. CD4+ T cell priming by DC subsets that is dependent upon the route of administration raises the possibility that vaccination approaches could be tailored to prime helper T cell immunity

Neutron Star Constraints on the H Dibaryon

We study the influence of a possible H dibaryon condensate on the equation of state and the overall properties of neutron stars whose population otherwise contains nucleons and hyperons. In particular, we are interested in the question of whether neutron stars and their masses can be used to say anything about the existence and properties of the H dibaryon. We find that the equation of state is softened by the appearance of a dibaryon condensate and can result in a mass plateau for neutron stars. If the limiting neutron star mass is about that of the Hulse-Taylor pulsar a condensate of H dibaryons of vacuum mass 2.2 GeV and a moderately attractive potential in the medium could not be ruled out. On the other hand, if the medium potential were even moderately repulsive, the H, would not likely exist in neutron stars. If neutron stars of about 1.6 solar mass were known to exist, attractive medium effects for the H could be ruled out. Certain ranges of dibaryon mass and potential can be excluded by the mass of the Hulse-Taylor pulsar which we illustrate graphically.Comment: Revised by the addition of a figure showing the region of dibaryon mass and potential excluded by the Hulse-Taylor pulsar. 18 pages, 11 figures, latex (submitted to Phys. Rev. C