26,189 research outputs found
A National Tax Bar: An End to the Attorney-Accountant Tax Turf War
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
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
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
Phonon spin-lattice relaxation times for uranium and neodymium ions in calcium fluorid
Use of cohesive elements in fatigue analysis
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
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
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/cm). 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
Parity Effect in a Small Superconducting Particle
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
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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