The Parsonage Allowance Exclusion: Past, Present, and Future

Religious freedom has played a pivotal role in the history and cultural development of the United States.\u27 Religion historically has been considered a fundamental aspect of American culture, resulting in the granting of numerous legal rights and privileges to religious personnel and institutions. These grants stem from the protections in the Bill of Rights and include privileges that, though of undoubted importance, are not known widely and may fail to provoke controversy to the same extent as perceived infringements or endorsements of religion.\u27 Section 107 of the Internal Revenue Code grants one of the lesser- known privileges. This statute permits a minister of the gospel to exclude from gross income either the rental value of a furnished home or rental allowance paid to the minister as compensation to the extent that it actually is used to provide a home. Section 107, also known as the parsonage allowance exclusion, historically has created little controversy, probably because it has had relatively little impact on tax revenues and is known primarily to its beneficiaries. In recent years, however, individuals who see its potential as a tax-avoiding device have paid increased attention to the exclusion. The government, seeking to preserve an ever, shrinking tax base, has taken strides to narrow the scope of the statute or eliminate it altogether. Given the Supreme Court\u27s recent church-state decisions, section 107 seems destined to receive even greater attention in the coming decade. This Note analyzes the current section 107-determining its roots, discussing its application and effect, and expressing concern about its future vitality. Part II examines the history of the statute. Part III analyzes current interpretation of the section to determine the criteria that guide the Internal Revenue Service (IRS) and the courts in their application of the statute. Part IV discusses events of the last decade including publicized abuses by mail-order ministries, as well as IRS and judicial decisions, that suggest future changes in the statute\u27s interpretation and application. Part IV also discusses various governmental efforts either to eliminate or to amend the reach of section 107. Finally, Part V examines the constitutionality of section 107 in light of recent Supreme Court decisions. Focusing on the major shift in establishment clause analysis evident in Supreme Court decisions since 1983, Part V first considers whether the exclusion passes constitutional muster under the Court\u27s old and new tests. Next, this Note specifically examines two recent Supreme Court tax exemption cases and suggests that section 107 fails to meet the enunciated first amendment standards. Finally, this Note concludes that section 107 in its present form faces an uncertain future and suggests that Congress should scrutinize the parsonage allowance exclusion and any other tax relief for ministers to the same degree as benefits enjoyed by any other taxpayer class

Interaction effects on 2D fermions with random hopping

We study the effects of generic short-ranged interactions on a system of 2D Dirac fermions subject to a special kind of static disorder, often referred to as ``chiral.'' The non-interacting system is a member of the disorder class BDI [M. R. Zirnbauer, J. Math. Phys. 37, 4986 (1996)]. It emerges, for example, as a low-energy description of a time-reversal invariant tight-binding model of spinless fermions on a honeycomb lattice, subject to random hopping, and possessing particle-hole symmetry. It is known that, in the absence of interactions, this disordered system is special in that it does not localize in 2D, but possesses extended states and a finite conductivity at zero energy, as well as a strongly divergent low-energy density of states. In the context of the hopping model, the short-range interactions that we consider are particle-hole symmetric density-density interactions. Using a perturbative one-loop renormalization group analysis, we show that the same mechanism responsible for the divergence of the density of states in the non-interacting system leads to an instability, in which the interactions are driven strongly relevant by the disorder. This result should be contrasted with the limit of clean Dirac fermions in 2D, which is stable against the inclusion of weak short-ranged interactions. Our work suggests a novel mechanism wherein a clean system, initially insensitive to interaction effects, can be made unstable to interactions upon the inclusion of weak static disorder.Comment: 16 pages, 10 figures; References added, figures enlarged; to be published in Phys. Rev.

Fragility of spectral flow for topological phases in non-Wigner-Dyson classes

Topological insulators and superconductors support extended surface states protected against the otherwise localizing effects of static disorder. Specifically, in the Wigner-Dyson insulators belonging to the symmetry classes A, AI, and AII, a band of extended surface states is continuously connected to a likewise extended set of bulk states forming a ``bridge'' between different surfaces via the mechanism of spectral flow. In this work we show that this principle becomes \emph{fragile} in the majority of non-Wigner-Dyson topological superconductors and chiral topological insulators. In these systems, there is precisely one point with granted extended states, the center of the band, $E=0$. Away from it, states are spatially localized, or can be made so by the addition of spatially local potentials. Considering the three-dimensional insulator in class AIII and winding number $\nu=1$ as a paradigmatic case study, we discuss the physical principles behind this phenomenon, and its methodological and applied consequences. In particular, we show that low-energy Dirac approximations in the description of surface states can be treacherous in that they tend to conceal the localizability phenomenon. We also identify markers defined in terms of Berry curvature as measures for the degree of state localization in lattice models, and back our analytical predictions by extensive numerical simulations. A main conclusion of this work is that the surface phenomenology of non-Wigner-Dyson topological insulators is a lot richer than that of their Wigner-Dyson siblings, extreme limits being spectrum wide quantum critical delocalization of all states vs. full localization except at the $E=0$ critical point. As part of our study we identify possible experimental signatures distinguishing between these different alternatives in transport or tunnel spectroscopy.Comment: 16 pages, 8 figure

An Investigation of School Socioeconomic Staus on adolescent Athletes\u27 Baseline and Post-Injury Concussion Assessments

Please enjoy Volume 5, Issue 1 of the JSMAHS. In this issue you will find Professional and under graduate research abstracts, case reports, and critically appraised topics. Thank you for viewing this 5th Annual OATA Special Editio

Metal-insulator transition from combined disorder and interaction effects in Hubbard-like electronic lattice models with random hopping

We uncover a disorder-driven instability in the diffusive Fermi liquid phase of a class of many-fermion systems, indicative of a metal-insulator transition of first order type, which arises solely from the competition between quenched disorder and interparticle interactions. Our result is expected to be relevant for sufficiently strong disorder in d = 3 spatial dimensions. Specifically, we study a class of half-filled, Hubbard-like models for spinless fermions with (complex) random hopping and short-ranged interactions on bipartite lattices, in d > 1. In a given realization, the hopping disorder breaks time reversal invariance, but preserves the special ``nesting'' symmetry responsible for the charge density wave instability of the ballistic Fermi liquid. This disorder may arise, e.g., from the application of a random magnetic field to the otherwise clean model. We derive a low energy effective field theory description for this class of disordered, interacting fermion systems, which takes the form of a Finkel'stein non-linear sigma model [A. M. Finkel'stein, Zh. Eksp. Teor. Fiz. 84, 168 (1983), Sov. Phys. JETP 57, 97 (1983)]. We analyze the Finkel'stein sigma model using a perturbative, one-loop renormalization group analysis controlled via an epsilon-expansion in d = 2 + epsilon dimensions. We find that, in d = 2 dimensions, the interactions destabilize the conducting phase known to exist in the disordered, non-interacting system. The metal-insulator transition that we identify in d > 2 dimensions occurs for disorder strengths of order epsilon, and is therefore perturbatively accessible for epsilon << 1. We emphasize that the disordered system has no localized phase in the absence of interactions, so that a localized phase, and the transition into it, can only appear due to the presence of the interactions.Comment: 47 pages, 25 figures; submitted to Phys. Rev. B. Long version of arXiv:cond-mat/060757

Infinitely stackable interconnect device and method

A device having the capability for electrical, thermal, optical, and fluidic interconnections to various layers is described. Through-substrate vias in the interconnect device are filled to enable electrical and thermal connection or optionally hermetically sealed relative to other surfaces to enable fluidic or optical connection. Optionally, optical components may be placed within the region in order to manipulate optical signals. Redistribution of electrical interconnection is accomplished on both top and bottom surfaces of the substrate of the interconnect chip

Slow imbalance relaxation and thermoelectric transport in graphene

We compute the electronic component of the thermal conductivity (TC) and the thermoelectric power (TEP) of monolayer graphene, within the hydrodynamic regime, taking into account the slow rate of carrier population imbalance relaxation. Interband electron-hole generation and recombination processes are inefficient due to the non-decaying nature of the relativistic energy spectrum. As a result, a population imbalance of the conduction and valence bands is generically induced upon the application of a thermal gradient. We show that the thermoelectric response of a graphene monolayer depends upon the ratio of the sample length to an intrinsic length scale l_Q, set by the imbalance relaxation rate. At the same time, we incorporate the crucial influence of the metallic contacts required for the thermopower measurement (under open circuit boundary conditions), since carrier exchange with the contacts also relaxes the imbalance. These effects are especially pronounced for clean graphene, where the thermoelectric transport is limited exclusively by intercarrier collisions. For specimens shorter than l_Q, the population imbalance extends throughout the sample; the TC and TEP asymptote toward their zero imbalance relaxation limits. In the opposite limit of a graphene slab longer than l_Q, at non-zero doping the TC and TEP approach intrinsic values characteristic of the infinite imbalance relaxation limit. Samples of intermediate (long) length in the doped (undoped) case are predicted to exhibit an inhomogeneous temperature profile, whilst the TC and TEP grow linearly with the system size. In all cases except for the shortest devices, we develop a picture of bulk electron and hole number currents that flow between thermally conductive leads, where steady-state recombination and generation processes relax the accumulating imbalance.Comment: 14 pages, 4 figure

Fragility of spectral flow for topological phases in non-Wigner-Dyson classes

Topological insulators and superconductors support extended surface states protected against the otherwise localizing effects of static disorder. Specifically, in the Wigner-Dyson insulators belonging to the symmetry classes A, AI, and AII, a band of extended surface states is continuously connected to a likewise extended set of bulk states forming a ``bridge'' between different surfaces via the mechanism of spectral flow. In this work we show that this principle becomes \emph{fragile} in the majority of non-Wigner-Dyson topological superconductors and chiral topological insulators. In these systems, there is precisely one point with granted extended states, the center of the band, E=0. Away from it, states are spatially localized, or can be made so by the addition of spatially local potentials. Considering the three-dimensional insulator in class AIII and winding number ν=1 as a paradigmatic case study, we discuss the physical principles behind this phenomenon, and its methodological and applied consequences. In particular, we show that low-energy Dirac approximations in the description of surface states can be treacherous in that they tend to conceal the localizability phenomenon. We also identify markers defined in terms of Berry curvature as measures for the degree of state localization in lattice models, and back our analytical predictions by extensive numerical simulations. A main conclusion of this work is that the surface phenomenology of non-Wigner-Dyson topological insulators is a lot richer than that of their Wigner-Dyson siblings, extreme limits being spectrum wide quantum critical delocalization of all states vs. full localization except at the E=0 critical point. As part of our study we identify possible experimental signatures distinguishing between these different alternatives in transport or tunnel spectroscopy