United States Trust Co. v. I.R.S.

During the course of its administration, an estate may receive income that is subject to federal income tax. When, and if, an estate receives such income the executor is faced with the task of filing the estate\u27s income tax return along with a number of related considerations. One of the more important considerations is the allocation of the burden of such tax between the beneficiaries of the estate and the estate itself. Subchapter J of the Internal Revenue Code provides the mechanism to allocate that burden between the beneficiaries and the estate. Generally, Subchapter J attempts to allocate the tax liability according to the amount of income the estate retains and the amount of income which it distributes to beneficiaries. It does so, generally, by providing the estate an income tax deduction for amounts of income distributed to beneficiaries. United States Trust Co. v. I.R.S. involved this precise issue. The estate sought to deduct income it had distributed to a charitable beneficiary so that it would not be subject to any income tax liability with respect to this income. The government challenged the validity of this deduction. The government contended that the tax liability relating to such income was totally eliminated, rather than being allocated, because the charitable beneficiary was exempt from federal income tax. In holding for the estate, the court rested its decision on a literal reading of the statutory framework of Subchapter J

Topology Optimization for Additive Manufacturing

This paper gives an overview of the issues and opportunities for the application of topology optimization methods for additive manufacturing (AM). The main analysis issues discussed are: how to achieve the maximum geometric resolution to allow the fine features easily manufacturable by AM to be represented in the optimization model; the manufacturing constraints to be considered, and the workflow modifications required to handle the geometric complexity in the post optimization stages. The main manufacturing issues discussed are the potential for realizing intermediate density regions, in the case of the solid isotropic material with penalization (SIMP) approach, the use of small scale lattice structures, the use of multiple material AM processes, and an approach to including support structure requirement as a manufacturing constraint.Mechanical Engineerin

Design framework for multifunctional additive manufacturing: placement and routing of three-dimensional printed circuit volumes

A framework for the design of additively manufactured (AM) multimaterial parts with embedded functional systems is presented (e.g., structure with electronic/electrical components and associated conductive paths). Two of the key strands of this proposed framework are placement and routing strategies, which consist of techniques to exploit the true-3D design freedoms of multifunctional AM (MFAM) to create 3D printed circuit volumes (PCVs). Example test cases are presented, which demonstrate the appropriateness and effectiveness of the proposed techniques. The aim of the proposed design framework is to enable exploitation of the rapidly developing capabilities of multimaterial AM

An Optimization Based Design Framework for Multi-Functional 3D Printing

This work investigates design analysis and optimization methods for the integration of active internal systems into a component for manufacture using multi-material 3D printing processes. This enables efficient design of optimal multifunctional components that exploit the design freedoms of additive manufacturing (AM). The main contributions of this paper are in two areas: 1) the automated placement and routing of electrical systems within the component volume and, 2) the accommodation of the effect of this system integration on the structural response of the part through structural topology optimization (TO). A novel voxel modeling approach was used to facilitate design flexibility and to allow direct mapping to the 3D printer jetting nozzles.Mechanical Engineerin

Sensing Subjective Well-being from Social Media

Subjective Well-being(SWB), which refers to how people experience the quality of their lives, is of great use to public policy-makers as well as economic, sociological research, etc. Traditionally, the measurement of SWB relies on time-consuming and costly self-report questionnaires. Nowadays, people are motivated to share their experiences and feelings on social media, so we propose to sense SWB from the vast user generated data on social media. By utilizing 1785 users' social media data with SWB labels, we train machine learning models that are able to "sense" individual SWB from users' social media. Our model, which attains the state-by-art prediction accuracy, can then be used to identify SWB of large population of social media users in time with very low cost.Comment: 12 pages, 1 figures, 2 tables, 10th International Conference, AMT 2014, Warsaw, Poland, August 11-14, 2014. Proceeding

Design Optimization Strategy for Multifunctional 3D Printing

An optimization based design methodology for the additive manufacture of multifunctional parts (for example, a structure with embedded electronic/electrical systems and associated conductive paths) is presented. This work introduces a coupled optimization strategy where Topology Optimization (TO) is combined with an automated placement and routing approach that enables determination of an efficient internal system configuration. This permits the effect of the incorporation of the internal system on the structural response of the part to be taken into account and therefore enables the overall optimization of the structure-system unit. An example test case is included in the paper to evaluate the optimization strategy and demonstrate the methods effectiveness. The capability of this method allows the exploitation of the manufacturing capability under development within the Additive Manufacturing (AM) community to produce 3D internal systems within complex structures.Mechanical Engineerin

Design framework for multifunctional additive manufacturing: coupled optimization strategy for structures with embedded functional systems

The driver for this research is the development of multi-material additive manufacturing processes that provide the potential for multi-functional parts to be manufactured in a single operation. In order to exploit the potential benefits of this emergent technology, new design, analysis and optimization methods are needed. This paper presents a method that enables in the optimization of a multifunctional part by coupling both the system and structural design aspects. This is achieved by incorporating the effects of a system, comprised of a number of connected functional components, on the structural response of a part within a structural topology optimization procedure. The potential of the proposed method is demonstrated by performing a coupled optimization on a cantilever plate with integrated components and circuitry. The results demonstrate that the method is capable of designing an optimized multifunctional part in which both the structural and system requirements are considered

Ozone Reduction Survey Results: The Spring & Summer 98 Executive Summary

Questions about the salience of issues and attitudes toward improving air quality

Ozone Reduction Survey Results: The Spring & Summer 98 Report

Results of the questions about the salience of issues and attitudes toward improving air quality

A novel approach to design lesion-specific stents for minimum recoil

Stent geometries are obtained by topology optimization for minimized compliance under different stenosis levels and plaque material types. Three levels of stenosis by cross-sectional area, i.e., 30%, 40%, and 50% and three different plaque material properties, i.e., calcified, cellular, and hypocellular, were studied. The raw optimization results were converted to clear design concepts and their performance was evaluated by implanting them in their respective stenosed artery types using finite element analysis. The results were compared with a generic stent in similar arteries, which showed that the new designs showed less recoil. This work provides a concept that stents could be tailored to specific lesions in order to minimize recoil and maintain a patent lumen in stenotic arteries