Policy Facts and Incidents of Ownership under Estate Tax Section 2042(2): The Legacy of \u3cem\u3eRhode Island Hospital Trust\u3c/em\u3e

This article focuses on Internal Revenue Code Section 2042(2), an Estate Tax provision which includes life insurance proceeds in the gross estate of an individual who dies possessing an incident of ownership in the policy. In the often cited United States v. Rhode Island Hospital Trust Company, 355 F.2d 7 (1st Cir. 1966), the Court of Appeals emphasized the pre-eminent role of policy facts (the terms of the contract of life insurance) in the determination of whether a decedent holds such an incident. There has been some confusion in the subsequent cases as to the degree to which it is permissible to look to factors beyond the terms of a life insurance policy to resolve questions of includability under section 2042(2). This article examines the treatment of outside factors in the decided cases, and demonstrates how results can vary depending on the nature of a particular factor and the effect that it has on the policy terms, i.e., whether the outside factor would effectively add a provision to, or delete a provision from, the contract of insurance. The author seeks to find order in the inconsistent case law and suggests a rational approach for dealing with the issue in the future

Band alignment of SnS/Zn(O,S) heterojunctions in SnS thin film solar cells

Band alignment is critical to the performance of heterojunction thin film solar cells. In this letter, we report band alignment studies of SnS/Zn(O,S) heterojunctions with various compositions of Zn(O,S). Valence band offsets (VBOs) are measured by femtosecond laser pump/probe ultraviolet photoelectron spectroscopy (fs-UPS) from which conduction band offsets (CBOs) are calculated by combining with band gaps obtained by optical transmission/reflection measurements. The SnS/Zn(O,S) heterojunctions with S/Zn ratios of 0.37 and 0.50 have desirable small positive CBOs, while a ratio of 0.64 produces an undesirable large positive CBO. The results are consistent with the device performance of SnS/Zn(O,S) solar cells.Chemistry and Chemical BiologyOther Research Uni

Band alignment of SnS/Zn(O,S) heterojunctions in SnS thin film solar cells

Band alignment is critical to the performance of heterojunction thin film solar cells. In this letter, we report band alignment studies of SnS/Zn(O,S) heterojunctions with various compositions of Zn(O,S). Valence band offsets (VBOs) are measured by femtosecond laser pump/probe ultraviolet photoelectron spectroscopy (fs-UPS) from which conduction band offsets (CBOs) are calculated by combining with band gaps obtained by optical transmission/reflection measurements. The SnS/Zn(O,S) heterojunctions with S/Zn ratios of 0.37 and 0.50 have desirable small positive CBOs, while a ratio of 0.64 produces an undesirable large positive CBO. The results are consistent with the device performance of SnS/Zn(O,S) solar cells.Chemistry and Chemical BiologyOther Research Uni

Chemical principles. Third edition.

PREFACE: This edition of Chemical Principles, like its predecessors, is designed to be used in a general university chemistry course which must provide both an overview of chemistry for nonspecialists and a sound foundation for later study for science or chemistry majors. Hence there are several survey chapters introducing different areas of chemistry, including inorganic, nuclear, organic, and biochemistry, and an attempt is made throughout the book to place chemistry in its historical and cultural setting. At the same time, the quantitative aspects of chemistry are presented in a manner consistent with their importance, in a way that will make it easy to build upon them in later courses. This is the first complete revision of Chemical Principles since the first edition was published in 1969. The authors have rethought and replanned the entire book, especially the first thirteen chapters, trying to make it a better pedagogical tool without losing the special viewpoints and flavor that made the earlier editions so successful. The history and the anecdotal asides that help to make the subject palatable have been retained, but they have been better segregated from the factual material for which a student will be held responsible

Panel Discussion: Expropriation, Threats of Expropriation and Developmental Policy

This panel discussion is a conversation about the place of expropriation in international law

Atomic layer deposition of Al-incorporated Zn(O,S) thin films with tunable electrical properties

Zinc oxysulfide, Zn(O,S), films grown by atomic layer deposition were incorporated with aluminum to adjust the carrier concentration. The electron carrier concentration increased up to one order of magnitude from 1019 to 1020 cm−3 with aluminum incorporation and sulfur content in the range of 0 ≤ S/(Zn+Al) ≤ 0.16. However, the carrier concentration decreased by five orders of magnitude from 1019 to 1014 cm−3 for S/(Zn+Al) = 0.34 and decreased even further when S/(Zn+Al) > 0.34. Such tunable electrical properties are potentially useful for graded buffer layers in thin-film photovoltaic applications.Chemistry and Chemical Biolog

Estimation of uncertainty in three-dimensional coordinate measurement by comparison with calibrated points

This paper details a method of estimating the uncertainty of dimensional measurement for a three-dimensional coordinate measurement machine. An experimental procedure was developed to compare three-dimensional coordinate measurements with calibrated reference points. The reference standard used to calibrate these reference points was a fringe counting interferometer with a multilateration-like technique employed to establish three-dimensional coordinates. This is an extension of the established technique of comparing measured lengths with calibrated lengths. Specifically a distributed coordinate measurement device was tested which consisted of a network of Rotary-Laser Automatic Theodolites (R-LATs), this system is known commercially as indoor GPS (iGPS). The method was found to be practical and was used to estimate that the uncertainty of measurement for the basic iGPS system is approximately 1 mm at a 95% confidence level throughout a measurement volume of approximately 10 m × 10 m × 1.5 m. © 2010 IOP Publishing Ltd

The Victorian Newsletter (Fall 1959)

The Victorian Newsletter is edited for the English X Group of the Modern Language Association by William E. Buckler, 737 East Building, New York University, New York 3, New York.Some pages are missing from this record