1,353 research outputs found
Redefining “Peril”—Abating the Interest on a Tax Deficiency for Good Faith Reliance on IRS Publications
Many taxpayers rely on guidance materials the IRS provides in order to comprehend the United States Tax Code and pay an accurate tax. However, many, if not all, of these taxpayers would likely be startled to learn that their reliance on these IRS guidance materials is perilous. That is, that reliance upon these guidance materials will not support a taxpayer’s tax treatment decisions if the IRS decides that the decisions were incorrect under substantive law. However, because the courts have not decisively concluded which financial consequences a taxpayer faces or escapes by relying on informal IRS guidance, “peril” remains undefined. Does the taxpayer face all three? Does she face the tax deficiency and the associated interest charges but escape the penalty? Does she face the deficiency but escape the penalty and interest? This Comment answers these questions by looking at how the IRS, the courts, and the Internal Revenue Code (the Code) currently define peril and then offers a proposed statutory amendment to redefine peril in a way that compromises governmental interests of justice and taxpayer concerns of fairness
Postwar Churches of Christ Mission Work: The Philippines as a Case Study
There was a large increase in the number of Churches of Christ missionaries and missionary efforts following World War II (WWII). There were also significant changes and developments in American religious culture following WWII—Churches of Christ were not exempt from these changes. This study examines the question of how postwar developments in American religion influenced missionary efforts of American Churches of Christ by looking at examples of American missionaries in the Philippines.
The study relies heavily on primary sources, including letters and news reports from archival collections, Churches of Christ periodicals, and email correspondence with people familiar with the main church leaders during this time. Secondary sources set the larger context of postwar American religious culture, especially using the historiographical model of “big religion,” to explain the postwar American religious context. Additionally, secondary sources describe the history of the debate over the use of institutions among Churches of Christ.
American Churches of Christ missionaries brought postwar developments in American religious culture (e.g., institutionalization and professionalization) with them to the mission field. Mainline Churches of Christ trained native preachers and built churches in the Philippines. Their “American” institutions and expectations created problems of reliance on American financial support, which negatively affected their work. Churches of Christ missionaries also brought American theological debates and disagreements with them to the mission field. The noninstitutional debate among American and Filipino members of the Churches of Christ in the Philippines provides a key interpretive lens for understanding the progress of the churches.
Postwar American Churches of Christ missionaries who went to the Philippines were influenced by developments and changes in postwar American religious life. These changes and developments directly influenced their missionary methods in the Philippines, created problems of reliance on U.S. financial support, and led to the introduction of American theological debates
A Personal Reflection on the Nature and Value of Public Memory in Holocaust Memorials
In this article I critically reflect on my experience with Holocaust memorials in Eastern Germany. When designing a memorial, there are many important questions for those building the memorial to consider. These questions include: What historical or social factors have contributed to the felt need for the creation of a memorial? What kind of thoughts, reactions, or emotional responses will the memorial evoke within the observer? Or, will the memorial provide the opportunity for physical or emotional interaction or a new understanding that is meaningful? In this analysis, I provide some historical background for the creation of memorials in East Germany and the desire to preserve and learn from the past. I then describe my personal experiences with and reactions to some of these memorials, and end with a cautionary reflection from East Germany about how public memory can be abused. Based on these experiences, I conclude that the best way to memorialize past atrocities is for designers to include a diversity of responses that are able to engage people in multiple ways, including cognitive and abstract representations of the event or people being memorialized
Shear Wave Velocity Profiles at Sites Liquefied by the 1999 Kocaeli, Turkey Earthquake
This paper presents shear wave velocity profiles for 15 sites liquefied by the 1999 Kocaeli, Turkey earthquake. These profiles are used in order to evaluate each liquefaction site by the simplified shear wave velocity procedure. This procedure allowed for the identification of a potentially liquefiable region within the subsurface at each site. Locating this region at each site allowed for the separation of soils that were too stiff to liquefy from soils that were soft enough to liquefy. Once these soft regions had been identified, they were evaluated to separate granular soils expected to liquefy, from fine-grained soils expected not to liquefy. At sites where actual soil samples were available, this was accomplished by using the Chinese Criteria and the Andrews and Martin Criteria. At sites where only CPT data were available, this was accomplished by developing profiles of soil behavior type index (lc).
Granular soil layers were located within the liquefiable region at 11 of the liquefaction test sites. It is assumed that these layers were the ones responsible for the observed liquefaction. The depth and thickness of each of these layers have been identified. However, at four of the liquefaction sites, only soils predicted as not susceptible to liquefaction were encountered. In these cases, the layer coming closest to fulfilling the Chinese Criteria and the Andrews and Martin Criteria was chosen as the one most likely to have liquefied. At each of these four sites, this layer appeared to be primarily made up of non-plastic silts having 2 ÎĽm clay contents ranging from 15 - 25
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