Toward a Practical Estate-Tax Exclusion for Family-Run Businesses: Analysis of Section 2033A and Proposal for Reform

In a previous work appearing in this Journal, the authors proposed an approach to estate and gift taxation that encourages productive behavior by the recipients of wealth. In this Article, the authors analyze, in the context of their earlier work, the new estate-tax exclusion for closely held businesses (section 2033A) created by the Taxpayer Relief Act of 1997. The authors describe the features of a practical family-run business exclusion and conclude that section 2033A, in its present form, fails as a practical exclusion. The authors catalogue those elements of section 2033A that should be retained and propose reforms of those elements that should be eliminated or changed

The Proper Role of the Estate and Gift Taxation of Closely Held Businesses

The authors argue that the goals of estate and gift taxation are not served by taxing closely held businesses when the recipient of the business actively participates in its operation. Further, the authors suggest that taxing closely held businesses tends to harm capital production. The authors propose an approach to estate and gift taxation that encourages productive behavior by the recipients of wealth

Probing Λ\LambdaCDM cosmology with the Evolutionary Map of the Universe survey

The Evolutionary Map of the Universe (EMU) is an all-sky survey in radio-continuum which uses the Australian SKA Pathfinder (ASKAP). Using galaxy angular power spectrum and the integrated Sachs-Wolfe effect, we study the potential of EMU to constrain models beyond $\Lambda$CDM (i.e., local primordial non-Gaussianity, dynamical dark energy, spatial curvature and deviations from general relativity), for different design sensitivities. We also include a multi-tracer analysis, distinguishing between star-forming galaxies and galaxies with an active galactic nucleus, to further improve EMU's potential. We find that EMU could measure the dark energy equation of state parameters around 35\% more precisely than existing constraints, and that the constraints on $f_{\rm NL}$ and modified gravity parameters will improve up to a factor $\sim2$ with respect to Planck and redshift space distortions measurements. With this work we demonstrate the promising potential of EMU to contribute to our understanding of the Universe.Comment: 15 pages (29 with references and appendices), 6 figures and 10 tables. Matches the published version. Minimal changes from previous versio

Possible Detection of OVI from the LMC Superbubble N70

We present FUSE observations toward four stars in the LMC superbubble N70 and compare these spectra to those of four comparison targets located in nearby field and diffuse regions. The N70 sight lines show OVI 1032 absorption that is consistently stronger than the comparison sight lines by ~60%. We attribute the excess column density (logN_OVI=14.03 cm^-2) to hot gas within N70, potentially the first detection of OVI associated with a superbubble. In a survey of 12 LMC sight lines, Howk et al. (2002a) concluded that there was no correlation between ISM morphology and N_OVI. We present a reanalysis of their measurements combined with our own and find a clear difference between the superbubble and field samples. The five superbubbles probed to date with FUSE show a consistently higher mean N_OVI than the 12 non-superbubble sight lines, though both samples show equivalent scatter from halo variability. Possible ionization mechanisms for N70 are discussed, and we conclude that the observed OVI could be the product of thermal conduction at the interface between the hot, X-ray emitting gas inside the superbubble and the cooler, photoionized material making up the shell seen prominently in Halpha. We calculate the total hydrogen density n_H implied by our OVI measurements and find a value consistent with expectations. Finally, we discuss emission-line observations of OVI from N70.Comment: 9 pages in emulateapj style. Accepted to Ap

The Santa Fe Light Cone Simulation Project: II. The Prospects for Direct Detection of the WHIM with SZE Surveys

Detection of the Warm-Hot Intergalactic Medium (WHIM) using Sunyaev-Zeldovich effect (SZE) surveys is an intriguing possibility, and one that may allow observers to quantify the amount of "missing baryons" in the WHIM phase. We estimate the necessary sensitivity for detecting low density WHIM gas with the South Pole Telescope (SPT) and Planck Surveyor for a synthetic 100 square degree sky survey. This survey is generated from a very large, high dynamic range adaptive mesh refinement cosmological simulation performed with the Enzo code. We find that for a modest increase in the SPT survey sensitivity (a factor of 2-4), the WHIM gas makes a detectable contribution to the integrated sky signal. For a Planck-like satellite, similar detections are possible with a more significant increase in sensitivity (a factor of 8-10). We point out that for the WHIM gas, the kinematic SZE signal can sometimes dominate the thermal SZE where the thermal SZE decrement is maximal (150 GHz), and that using the combination of the two increases the chance of WHIM detection using SZE surveys. However, we find no evidence of unique features in the thermal SZE angular power spectrum that may aid in its detection. Interestingly, there are differences in the power spectrum of the kinematic SZE, which may not allow us to detect the WHIM directly, but could be an important contaminant in cosmological analyses of the kSZE-derived velocity field. Corrections derived from numerical simulations may be necessary to account for this contamination.Comment: 9 pages, submitted to Astrophysical Journa

Cosmic Origins Spectrograph and FUSE Observations of T ~ 10^5 K Gas In A Nearby Galaxy Filament

We present a detection of a broad Ly-alpha absorber (BLA) with a matching O VI line in the nearby universe. The BLA is detected at z = 0.01028 in the high S/N spectrum of Mrk 290 obtained using the Cosmic Origins Spectrograph. The Ly-alpha absorption has two components, with b(HI) = 55 +/- 1 km/s and b(HI) = 33 +/- 1 km/s, separated in velocity by v ~ 115 km/s. The O VI, detected by FUSE at z = 0.01027, has a b(OVI) = 29 +/- 3 km/s and is kinematically well aligned with the broader HI component. The different line widths of the BLA and OVI suggest a temperature of T = 1.4 x 10^5 K in the absorber. The observed line strength ratios and line widths favor an ionization scenario in which both ion-electron collisions and UV photons contribute to the ionization in the gas. Such a model requires a low-metallicity of -1.7 dex, ionization parameter of log U ~ -1.4, a large total hydrogen column density of N(H) ~ 4 x 10^19 cm^-2, and a path length of 400 kpc. The line of sight to Mrk 290 intercepts at the redshift of the absorber, a megaparsec scale filamentary structure extending over 20 deg in the sky, with several luminous galaxies distributed within 1.5 Mpc projected distance from the absorber. The collisionally ionized gas in this absorber is likely tracing a shock-heated gaseous structure, consistent with a few different scenarios for the origin, including an over-dense region of the WHIM in the galaxy filament or highly ionized gas in the extended halo of one of the galaxies in the filament. In general, BLAs with metals provide an efficient means to study T ~ 10^5 - 10^6 K gas in galaxy halos and in the intergalactic medium. A substantial fraction of the baryons "missing" from the present universe is predicted to be in such environments in the form of highly ionized plasma.Comment: Astrophysical Journal Accepte

The Ultraviolet Detection of Diffuse Gas in Galaxy Groups

A small survey of the UV-absorbing gas in 12 low-$z$ galaxy groups has been conducted using the Cosmic Origins Spectrograph (COS) on-board the Hubble Space Telescope (HST). Targets were selected from a large, homogeneously-selected sample of groups found in the Sloan Digital Sky Survey (SDSS). A critical selection criterion excluded sight lines that pass close ($<1.5$ virial radii) to a group galaxy, to ensure absorber association with the group as a whole. Deeper galaxy redshift observations are used both to search for closer galaxies and also to characterize these $10^{13.5}$ to $10^{14.5} M_{\odot}$ groups, the most massive of which are highly-virialized with numerous early-type galaxies (ETGs). This sample also includes two spiral-rich groups, not yet fully-virialized. At group-centric impact parameters of 0.3-2 Mpc, these $\mathrm{S/N}=15$-30 spectra detected HI absorption in 7 of 12 groups; high (OVI) and low (SiIII) ion metal lines are present in 2/3 of the absorption components. None of the three most highly-virialized, ETG-dominated groups are detected in absorption. Covering fractions $\gtrsim50$% are seen at all impact parameters probed, but do not require large filling factors despite an enormous extent. Unlike halo clouds in individual galaxies, group absorbers have radial velocities which are too low to escape the group potential well without doubt. This suggests that these groups are "closed boxes" for galactic evolution in the current epoch. Evidence is presented that the cool and warm group absorbers are not a pervasive intra-group medium (IGrM), requiring a hotter ($T\sim10^6$ to $10^7$ K) IGrM to be present to close the baryon accounting.Comment: Resubmitted to ApJS after first review; 82 pages (27 for main text, rest are Appendices and supplemental figures and tables), 47 figures, 21 table