The Supreme Court, Due Process and State Income Taxation of Trusts

What are the constitutional limits on a state\u27s power to tax a trust with no connection to the state, other than the accident that a potential beneficiary lives there? The Supreme Court of the United States will take up this question this term in the context of North Carolina Department of Revenue v. Kimberley Rice Kaestner 1992 Family Trust. The case involves North Carolina\u27s income taxation of a trust with a contingent beneficiary, meaning someone who is eligible, but not certain, to receive a distribution or benefit from the trust, who resides in that state. Part I of this Article explains the background of Kaestner Trust and frames the constitutional questions that will be before the Court at oral arguments on April 16, 2019. Part II examines how and why due process applies in the state income taxation context, with a particular emphasis on how familiar concepts of general and specific jurisdiction apply uneasily to donative trusts. Part III articulates the reasons that the Court should hold that a state has no constitutional authority to impose a tax on trust income where the trust\u27s only connection with the forum state is the residence of a contingent beneficiary. Kaestner Trust is the most important due process case involving trusts that the Court has decided in over sixty years; it bears directly on the fundamental meaning of due process

Hybrid receiver conceptual design and test report

The Hybrid Receiver described uses an acquisition and demodulation scheme tailored to the Jovian environment. The large Doppler offsets expected during initial acquisition led to development of the Hilbert Acquisition Aid, which provides for rapid acquisition for low signal to noise densities

Langmuir probe measurements of double-layers in a pulsed discharge

Langmuir probe measurements were carried out which confirm the occurrence of double-layers in an argon positive column. Pulsing the discharge current permitted probe measurements to be performed in the presence of the double-layer. Supplementary evidence, obtained from DC and pulsed discharges, indicated that the double-layers formed in the two modes of operation were similar. The double-layers observed were weak and stable; their relation to other classes of double-layers are discussed, and directions for future work are suggested

A fluid description of plasma double-layers

The space-charge double-layer that forms between two plasmas with different densities and thermal energies was investigated using three progressively realistic models which are treated by fluid theory, and take into account four species of particles: electrons and ions reflected by the double-layer, and electrons and ions transmitted through it. The two plasmas are assumed to be cold, and the self-consistent potential, electric field and space-charge distributions within the double-layer are determined. The effects of thermal velocities are taken into account for the reflected particles, and the modifications to the cold plasma solutions are established. Further modifications due to thermal velocities of the transmitted particles are examined. The applicability of a one dimensional fluid description, rather than plasma kinetic theory, is discussed. Theoretical predictions are compared with double layer potentials and lengths deduced from laboratory and space plasma experiments

A deep Chandra observation of the cluster environment of the z=1.786 radio galaxy 3C294

We report the results from a 200 ks Chandra observation of the z=1.786 radio galaxy 3C294 and its cluster environment, increasing by tenfold our earlier observation. The diffuse emission, extending about 100 kpc around the nucleus, has a roughly hourglass shape in the N-S direction with surprisingly sharp edges to the N and S. The spectrum of the diffuse emission is well fitted by either a thermal model of temperature 3.5 keV and abundance <0.9 solar (2-sigma), or a power-law with photon index 2.3. If the emission is due to hot gas then the sharp edges mean that it is probably not in hydrostatic equilibrium. Much of the emission is plausibly due to inverse Compton scattering of the Cosmic Microwave Background (CMB) by nonthermal electrons produced earlier by the radio source. The required relativistic electrons would be of much lower energy and older than those responsible for the present radio lobes. This could account for the lack of detailed spatial correspondence between the X-rays and the radio emission, the axis of which is at a position angle of about 45 deg. Hot gas would still be required to confine the relativistic plasma; the situation could parallel that of the radio bubbles seen as holes in nearby clusters, except that in 3C294 the bubbles are bright in X-rays owing to the extreme power in the source and the sixty fold increase in the energy density of the CMB. The X-ray spectrum of the radio nucleus is hard, showing a reflection spectrum and iron line. The source is therefore an obscured radio-loud quasar.Comment: In press (MNRAS), 10 pages, 12 figures (2 colour

SMC SMP 24: A newly radio-detected planetary nebula in the small magellanic cloud

In this paper we report new radio-continuum detection of an extragalactic PN: SMC SMP 24. We show the radio-continuum image of this PN and present the measured radio data. The newly reduced radio observations are consistent with the multi-wavelength data and derived parameters found in the literature. SMC SMP 24 appear to be a young and compact PN, optically thick at frequencies below 2 GHz.Comment: accepted for publication in Serbian Astronomical Journa

A sensitive genetic-based detection capability for Didymosphenia geminata

It is now well recognized that the increase in global transportation over the last two decades has brought with it an increased potential for the introduction of unwanted microorganisms (aquatic or terrestrial) that may have drastic effects on human and ecosystem health and agriculture. We have developed and validated a unique genetic fingerprinting tool for D. geminata. In concert, we developed field collection and preservation techniques specific for D. geminata along with genetic-based procedures that can now reliably detect D. geminate from a complex environmental community with a high degree of sensitivity. Recent work (Phase 2) has shown that the described methods will provide detection levels from <1 – 10,000 cells ml-1. We contend that the genetic based detection approaches used in this study offer great promise to meet the increasing demands to monitor the global threat from invasive micro-organisms

Homoclinic snaking in bounded domains

Homoclinic snaking is a term used to describe the back and forth oscillation of a branch of time-independent spatially localized states in a bistable, spatially reversible system as the localized structure grows in length by repeatedly adding rolls on either side. On the real line this process continues forever. In finite domains snaking terminates once the domain is filled but the details of how this occurs depend critically on the choice of boundary conditions. With periodic boundary conditions the snaking branches terminate on a branch of spatially periodic states. However, with non-Neumann boundary conditions they turn continuously into a large amplitude filling state that replaces the periodic state. This behavior, shown here in detail for the Swift-Hohenberg equation, explains the phenomenon of “snaking without bistability”, recently observed in simulations of binary fluid convection by Mercader, Batiste, Alonso and Knobloch (preprint)

Scaling and singularities in the entrainment of globally-coupled oscillators

The onset of collective behavior in a population of globally coupled oscillators with randomly distributed frequencies is studied for phase dynamical models with arbitrary coupling. The population is described by a Fokker-Planck equation for the distribution of phases which includes the diffusive effect of noise in the oscillator frequencies. The bifurcation from the phase-incoherent state is analyzed using amplitude equations for the unstable modes with particular attention to the dependence of the nonlinearly saturated mode $|\alpha_\infty|$ on the linear growth rate $\gamma$. In general we find $|\alpha_\infty|\sim \sqrt{\gamma(\gamma+l^2D)}$ where $D$ is the diffusion coefficient and $l$ is the mode number of the unstable mode. The unusual $(\gamma+l^2D)$ factor arises from a singularity in the cubic term of the amplitude equation.Comment: 11 pages (Revtex); paper submitted to Phys. Rev. Let

Atomic Gas in Debris Discs

We have conducted a search for optical circumstellar absorption lines in the spectra of 16 debris disc host stars. None of the stars in our sample showed signs of emission line activity in either H$_{\alpha}$, Ca II or Na I, confirming their more evolved nature. Four stars were found to exhibit narrow absorption features near the cores of the photospheric Ca II and Na I D lines (when Na I D data were available). We analyse the characteristics of these spectral features to determine whether they are of circumstellar or interstellar origins. The strongest evidence for circumstellar gas is seen in the spectrum of HD110058, which is known to host a debris disc observed close to edge-on. This is consistent with a recent ALMA detection of molecular gas in this debris disc, which shows many similarities to the $\beta$ Pictoris system.Comment: Accepted 13/12/2016. Received 2/12/2016; Deposited on 22/11/2016. - 13 Pages, 9 Figures - MNRAS Advance Access published December 15, 201