Deductibility of Prepaid IDC after Keller

In recent years, the Internal Revenue Service has succeeded in eliminating a number of tax-sheltering mechanisms by employing both changes in the tax laws and zealous-some would say overzealous-enforcement of tax law interpretations. While some of these mechanisms may have been abusive, others which were harmless and productive have also fallen victim to the wholesale assault. In July of 1982, with the Tax Court\u27s decision in Keller v. Commissioner, one of the most widespread and traditionally favored tax-shelter vehicles, the oil and gas exploratory drilling fund, was placed on the endangered species list, its ultimate fate as yet undeterminable. Section II provides general background information on tax shelters and the oil and gas drilling limited partnership. Section III then lays out the history of intangible drilling and development costs (IDC) deductibility. Section IV begins the discussion of the Keller case, with Section V analyzing Keller under the previously established guidelines. Section VI moves on to discuss the new standard laid out by the Keller two-part test, and Section VII analyzes the Ninth Circuit’s one-year rule

Numerical solution to the hermitian Yang-Mills equation on the Fermat quintic

We develop an iterative method for finding solutions to the hermitian Yang-Mills equation on stable holomorphic vector bundles, following ideas recently developed by Donaldson. As illustrations, we construct numerically the hermitian Einstein metrics on the tangent bundle and a rank three vector bundle on P^2. In addition, we find a hermitian Yang-Mills connection on a stable rank three vector bundle on the Fermat quintic.Comment: 25 pages, 2 figure

A Digital Neuromorphic Architecture Efficiently Facilitating Complex Synaptic Response Functions Applied to Liquid State Machines

Information in neural networks is represented as weighted connections, or synapses, between neurons. This poses a problem as the primary computational bottleneck for neural networks is the vector-matrix multiply when inputs are multiplied by the neural network weights. Conventional processing architectures are not well suited for simulating neural networks, often requiring large amounts of energy and time. Additionally, synapses in biological neural networks are not binary connections, but exhibit a nonlinear response function as neurotransmitters are emitted and diffuse between neurons. Inspired by neuroscience principles, we present a digital neuromorphic architecture, the Spiking Temporal Processing Unit (STPU), capable of modeling arbitrary complex synaptic response functions without requiring additional hardware components. We consider the paradigm of spiking neurons with temporally coded information as opposed to non-spiking rate coded neurons used in most neural networks. In this paradigm we examine liquid state machines applied to speech recognition and show how a liquid state machine with temporal dynamics maps onto the STPU-demonstrating the flexibility and efficiency of the STPU for instantiating neural algorithms.Comment: 8 pages, 4 Figures, Preprint of 2017 IJCN

A note on monopole moduli spaces

We discuss the structure of the framed moduli space of Bogomolny monopoles for arbitrary symmetry breaking and extend the definition of its stratification to the case of arbitrary compact Lie groups. We show that each stratum is a union of submanifolds for which we conjecture that the natural $L^2$ metric is hyperKahler. The dimensions of the strata and of these submanifolds are calculated, and it is found that for the latter, the dimension is always a multiple of four.Comment: 17 pages, LaTe

Bergman Kernel from Path Integral

We rederive the expansion of the Bergman kernel on Kahler manifolds developed by Tian, Yau, Zelditch, Lu and Catlin, using path integral and perturbation theory, and generalize it to supersymmetric quantum mechanics. One physics interpretation of this result is as an expansion of the projector of wave functions on the lowest Landau level, in the special case that the magnetic field is proportional to the Kahler form. This is relevant for the quantum Hall effect in curved space, and for its higher dimensional generalizations. Other applications include the theory of coherent states, the study of balanced metrics, noncommutative field theory, and a conjecture on metrics in black hole backgrounds. We give a short overview of these various topics. From a conceptual point of view, this expansion is noteworthy as it is a geometric expansion, somewhat similar to the DeWitt-Seeley-Gilkey et al short time expansion for the heat kernel, but in this case describing the long time limit, without depending on supersymmetry.Comment: 27 page

Geophysical Surveys Across the Boise Hydrogeophysical Research Site to Determine Geophysical Parameters of a Shallow, Alluvial Aquifer

At the Boise Hydrogeophysical Research Site (BHRS), we are characterizing the hydrogeophysical parameters of a cobble-and-sand, unconfined aquifer using a wide variety of geophysical methods. Our goal is to develop methods for mapping variations in permeability by combining non-invasive geophysical data with hydrologic measurements. We are using seismic, ground penetrating radar, and electrical methods in a variety of configurations to provide images of and parameter distributions at the BHRS. Issues such as resolution, depth of penetration, and the ability to image the desired parameters will help determine the most effective methods. Supporting data sets from the BHRS include core analyses and geophysical logs from 18 wells at the site. We will use these data to verify our geophysical interpretations. The various geophysical methods and acquisition geometries, combined with the well control, will provide an outstanding data set to characterize the heterogeneity of the subsurface beneath this alluvial aquifer, and find ways to map permeability with geophysical information

Use of a Distal Radius Endoprosthesis Following Resection of a Bone Tumour: A Case Report

Limited literature is available on the reconstruction of the distal radius using prosthetic replacement following resection of a bone tumour. We present the first reported case, in the English literature, of the use of an entirely metal endoprosthesis for the reconstruction of the distal radius. This case involves a 66-year-old male who was treated for giant cell tumour of the distal radius with surgical excision of the lesion and replacement of the defect using a predominantly titanium endoprosthesis. He was followed-up for 56 months following surgery and had a good functional outcome with no associated pain or complications. We propose that the use of a primarily titanium endoprosthesis for the reconstruction of a bone defect of the distal radius is a suitable alternative, providing good function of the forearm with satisfactory range of movement at the wrist and adequate pain relief

Lake Breezes in Southern Ontario and Their Relation to Tornado Climatology

Geostationary Operational Environmental Satellite (GOES) imagery is used to demonstrate the development of lake-breeze boundaries in southern Ontario under different synoptic conditions. The orientation of the gradient wind with respect to the shorelines is important in determining the location of such lines. When moderate winds (5–10 m s21) are parallel to straight sections of coastlines, cloud lines can extend well inland. In the region between Lakes Huron and Erie lake-breeze lines merge frequently, sometimes resulting in long-lasting stationary storms and attendant heavy rain and flooding. The influence of the lakes is apparent in the tornado climatology for the region: tornadoes appear to be suppressed in regions visited by lake-modified air and enhanced in regions favored by lake-breeze convergence lines. The cloud patterns in the case of a cold front interacting with merging lake-breeze boundaries are shown to be similar to those on a major tornado outbreak day. Two of the cases discussed are used as conceptual models to explain many of the features in the patterns of tornado touchdown locations. In general, it appears that the lakes suppress tornadoes in southern Ontario, compared with neighboring states and in particular in areas where southwest winds are onshore, but enhance tornado likelihood locally in areas of frequent lake-breeze activity. 1

Listeria Occurrence In Poultry Flocks: Detection and Potential Implications

Foodborne pathogens such as Salmonella, Campylobacter, Escherichia coli, and Listeria are a major concern within the food industry due to their pathogenic potential to cause infection. Of these, Listeria monocytogenes, possesses a high mortality rate (approximately 20%) and is considered one of the most dangerous foodborne pathogens. Although the usual reservoirs for Listeria transmission have been extensively studied, little is known about the relationship between Listeria and live poultry production. Sporadic and isolated cases of listeriosis have been attributed to poultry production and Listeria spp. have been isolated from all stages of poultry production and processing. Farm studies suggest that live birds may be an important vector and contributor to contamination of the processing environment and transmission of Listeria to consumers. Therefore, the purpose of this review is to highlight the occurrence, incidence, and potential systemic interactions of Listeria spp. with poultry

Instantons and Chiral Symmetry on the Lattice

I address the question of how much of QCD in the chiral limit is reproduced by instantons. After reconstructing the instanton content of smoothed Monte Carlo lattice configurations, I compare hadron spectroscopy on this instanton ensemble to the spectroscopy on the original ``physical'' smoothed configurations using a chirally optimised clover fermion action. By studying the zero mode zone in simple instances I find that the optimised action gives a satisfactory description of it. Through the Banks-Casher formula, instantons by themselves are shown to break chiral symmetry but hadron correlators on the instanton backgrounds are strongly influenced by free quark propagation. This results in unnaturally light hadrons and a small splitting between the vector and the pseudoscalar meson channels. Superimposing a perturbative ensemble of zero momentum gauge field fluctuations (torons) on the instantons is found to be enough to eliminate the free quarks and restore the physical hadron correlators. I argue that the torons that are present only in finite volumes, are probably needed to compensate the unnaturally large finite size effects due to the lack of confinement in the instanton ensemble.Comment: 32 pages, LaTeX with 14 eps figure