Long distance tracking of birds

The application of radio telemetry techniques to the long distance tracking of birds is discussed. The types of equipment developed and methods for attachment to a bird are described. The operating range of the radio transmitter receiver system is examined, and methods for acquiring and analyzing the data are explained

A high pressure, high temperature combustor and turbine-cooling test facility

A new test facility is being constructed for developing turbine-cooling and combustor technology for future generation aircraft gas turbine engines. Prototype engine hardware will be investigated in this new facility at gas stream conditions up to 2480 K average turbine inlet temperature and 4.14 x 10 to the 6th power n sq m turbine inlet pressure. The facility will have the unique feature of fully automated control and data acquisition through the use of an integrated system of mini-computers and programmable controllers which will result in more effective use of operating time, will limit the number of operators required, and will provide built in self protection safety systems. The facility and the planning and design considerations are described

Engineering multiferroism in CaMnO3_3

From first-principles calculations, we investigate the structural instabilities of CaMnO$_3$. We point out that, on top of a strong antiferrodistortive instability responsible for its orthorhombic ground-state, the cubic perovskite structure of CaMnO$_3$ also exhibit a weak ferroelectric instability. Although ferroelectricity is suppressed by antiferrodistortive oxygen motions, we show that it can be favored using strain or chemical engineering in order to make CaMnO$_3$ multiferroic. We finally highlight that the FE instability of CaMnO$_3$ is Mn-dominated. This illustrates that, contrary to the common believe, ferroelectricity and magnetism are not necessarily exclusive but can be driven by the same cation

Strain-induced ferroelectricity in simple rocksalt binary oxides

The alkaline earth binary oxides adopt a simple rocksalt structure and form an important family of compounds because of their large presence in the earth's mantle and their potential use in microelectronic devices. In comparison to the class of multifunctional ferroelectric perovskite oxides, however, their practical applications remain limited and the emergence of ferroelectricity and related functional properties in simple binary oxides seems so unlikely that it was never previously considered. Here, we show using first-principles density functional calculations that ferroelectricity can be easily induced in simple alkaline earth binary oxides such as barium oxide (BaO) using appropriate epitaxial strains. Going beyond the fundamental discovery, we show that the functional properties (polarization, dielectric constant and piezoelectric response) of such strained binary oxides are comparable in magnitude to those of typical ferroelectric perovskite oxides, so making them of direct interest for applications. Finally, we show that magnetic binary oxides such as EuO, with the same rocksalt structure, behave similarly to the alkaline earth oxides, suggesting a route to new multiferroics combining ferroelectric and magnetic properties

Cadillacs, Gold Watches, and the Tax Reform Act of 1986: The Continuing Evolution of the Tax Treatment of Gifts to Employees

To eliminate uncertainty for taxpayers and inconsistency from the courts, Congress passed the Tax Reform Act of 1986, which is applicable to “gifts” from employers to employees. Congress added three Internal Revenue Code provisions applicable to such gifts. First, Section 102 sets forth a general rule that property transferred by an employer to an employee shall not be excluded from the employee’s gross income as a gift. Second, Section 74 potentially excludes certain retirement awards. Third, Section 274 limits an employer’s deductions for such retirement awards. These three provisions should mark the end of many years of uncertainty for taxpayers and inconsistency on the part of the courts, Congress, and the Commissioner. At the same time, the new provisions, like any new legislation, give rise to new uncertainties. Historically, uncertainty and inconsistency have characterized the tax treatment of gifts to employees. Courts, Congress, and the Internal Revenue Service have all contributed to the confusion over whether an employee may exclude from gross income the value of a gift from his employer, and whether the employer may deduct the cost of such a gift as a business expense. Even with the guidance provided in Commissioner v. Duberstein, holding that an excludible gift must proceed from “detached and disinterested generosity,” courts continued to reach widely varying results in seemingly similar fact patterns. Shortly after Duberstein was decided, Congress enacted a dollar limitation on the deductibility of gifts as a business expense. This implied that a gift might be both deductible by the donor and excludable by the doneee. Next, Congress adopted a blanket rule that transfers to employees are not excludable from the employee’s gross income as gifts, which finalized the Tax Reform Act of 1986 and resolved much of the uncertainty that previously existed

Should Personal Injury Damage Awards Be Taxed?

The exclusion of personal injury damage awards from gross income is inconsistent with established principles of taxation. Section 104(a)(2) of the Internal Revenue Code excludes from gross income “the amount of any damages received . . . on account of personal injury or sickness.” While the existence of Section 104(a)(2) traditionally has been justified as a humanitarian gesture, more logical explanations have been offered. Damage awards cannot accurately be characterized as a return of capital. Nor does the involuntary nature of the transaction justify the exclusion. While so-called imputed income is not taxed, the reasons supporting its non-taxability do not extend to damage awards representing a cash substitute for such income. Excluding damage awards avoids certain administrative problems that may otherwise arise, but those problems could be resolved by less drastic means. These justifications for the exclusion cannot be rationalized as a logical application of tax theory. To the extent that such a justification is lacking, the exclusion should be evaluated as a tax subsidy. Although Congress did not originally intend the exclusion to be a subsidy, it functions as such in the context of modern tax law. The exclusion provided by Section 104(a)(2) compensates tort victims by allowing receipts that logically should be included in gross income to escape taxation. While an expenditure of government funds for the benefit of innocent tort victims has emotional appeal, a closer inspection of the ramifications of the subsidy reveals that it is not a wise investment of public resources. The subsidy is not fairly allocated and the government subsidization of injuries is contrary to sound tort policy. If damage awards were taxed, the policy goals of the tort system would be advanced rather than frustrated, since defendants would not be under-penalized and plaintiffs would not be overcompensated

Back to the Future: Marriage and Divorce under the 2017 Tax Act

The Tax Cuts and Jobs Act of 2017 (the 2017 Tax Act) significantly altered the federal tax consequences of marriage and divorce by mostly eliminating the so-called marriage penalty from the individual income tax rates and abolishing the deduction for alimony payments. These changes represent the latest congressional tinkering with issues that have persisted since the earliest days of the modem income tax, turning back the clock with regard to taxation for both married and divorced couples. For the first time, since the enactment of the Tax Reform Act of 1969, the rate brackets for married taxpayers filing joint returns are twice as wide as the brackets applicable to unmarried taxpayers. For the first time since 1942, alimony payments are not deductible by the payor and not includable in the recipient\u27s gross income. The significance of these changes can best be appreciated by examining their historical context, and this article will undertake that examination