26,189 research outputs found

    A National Tax Bar: An End to the Attorney-Accountant Tax Turf War

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    Although current case law is divided regarding when an accountant is practicing law, this Article will explore different approaches to this problem. Specifically, Part II of this Article explores which entities control the regulation of the legal profession. Next, Part III examines the impact of the state courts on the issue of unauthorized legal practice. Part IV touches on the related issue of privilege and the treatment of attorney-client privilege in the context of tax practice. Further, Part V considers whether tax practice should be considered the practice of law, and Part VI of this Article examines the legal profession\u27s obligation to regulate the practice of law. Finally, Part VII proposes new educational requirements and the establishment of a tax bar to assure the public of some minimum standard of education and competency in the area of taxation

    Justice Scalia\u27s Tax Jurisprudence

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    Justice Scalia is an outspoken conservative acclaimed for his remarkable intellect and scholarship, and is noted for his adherence to the principle of judicial restraint. He pursues what he insists is an originalist path that relies on the Constitution\u27s actual text in decision-making. He works hard to try to maintain constitutional interpretation that does not change from case to case. So what happens when an originalist --concerned that Congress writes imprecise legislation and then leaves its interpretation and application in the hands of administrative agencies or, worse yet, the courts-is forced to deal with tax issues? This article takes a look at whether Scalia has been successful in trying to construct a coherent theory of constitutional interpretation that does not change from case to case, when those cases involve tax issues

    Spin-lattice interactions of ions with unfilled F-shells measured by ESR in uniaxially stressed crystals

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    Spin-lattice interactions of ions with unfilled F-shells measured by electron spin resonance in uniaxially stressed crystal

    Direct one-phonon spin-lattice relaxation times for Nd sup 3 plus and U sup 3 plus ions in CaF sub 2 in sites of tetragonal symmetry

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    Phonon spin-lattice relaxation times for uranium and neodymium ions in calcium fluorid

    Use of cohesive elements in fatigue analysis

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    Cohesive laws describe the resistance to incipient separation of material surfaces. A cohesive finite element is formulated on the basis of a particular cohesive law. Cohesive elements are placed at the boundary between adjacent standard volume finite elements to model fatigue damage that leads to fracture at the separation of the element boundaries per the cohesive law. In this work, a cohesive model for fatigue crack initiation is taken to be the irreversible loadingunloading hysteresis that represents fatigue damage occuring due to cyclic loads leading to the initiation of small cracks. Various cohesive laws are reviewed and one is selected that incorporates a hysteretic cyclic loading that accounts for energetic dissipative mechanisms. A mathematical representation is developed based on an exponential effective load-separation cohesive relationship. A three-dimensional cohesive element is defined using this compliance relationship integrated at four points on the mid-surface of the area element. Implementation into finite element software is discussed and particular attention is applied to numerical convergence issues as the inflection point between loading and 'unloading in the cohesive law is encountered. A simple example of a displacementcontrolled fatigue test is presented in a finite element simulation. Comments are made on applications of the method to prediction of fatigue life for engineering structures such as pressure vessels and piping

    Models for application of radiation boundary condition for MHD waves in collapse calculations

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    The problem of reflection of magnetohydrodynamic (MHD) waves at the boundary of a numerical grid has to be resolved in order to obtain reliable results for the end state of the (isothermal) collapse of a rotating, magnetic protostellar cloud. Since the goal of investigating magnetic braking in collapse simulations is to see if the transport of angular momentum via alfven waves is large enough to solve the angular momentum problem an approximation that artificially suppresses large amplitudes in the MHD waves can be self-defeating. For this reason, four alternate methods of handling reflected waves where no assumptions are made regarding the amplitudes of the waves were investigated. In order to study this problem (of reflection) without interference from other effects these methods were tried on two simpler cases. The four methods are discussed

    Light forces in ultracold photoassociation

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    We study the time-resolved photoassociation of ultracold sodium in an optical dipole trap. The photoassociation laser excites pairs of atoms to molecular states of large total angular momentum at high intensities (above 20 kW/cm2^{2}). Such transitions are generally suppressed at ultracold temperatures by the centrifugal barriers for high partial waves. Time-resolved ionization measurements reveal that the atoms are accelerated by the dipole potential of the photoassociation beam. We change the collision energy by varying the potential depth, and observe a strong variation of the photoassociation rate. These results demonstrate the important role of light forces in cw photoassociation at high intensities.Comment: 7 pages, 3 figure

    Is the IRS the Solution to Illegal Immigration?

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    Parity Effect in a Small Superconducting Particle

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    Matveev and Larkin calculated the parity effect on the ground state energy of a small superconducting particle in the regimes where the mean level spacing is either large or small compared to the bulk gap. We perform a numerical calculation which extends their results into the intermediate regime, where the level spacing is of the same order as the bulk gap.Comment: 6 LaTeX pages, including 2 EPS figures; corrected reference and spellin

    Microwave Remote Sensing of Ocean Surface Wind Speed and Rain Rates over Tropical Storms

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    The value of using narrowly spaced frequencies within a microwave band to measure wind speeds and rain rates over tropical storms with radiometers is reviewed. The technique focuses on results obtained in the overflights of Hurricane Allen during 5 and 8 of August, 1980
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