Taxed Structured Settlements

Congress has granted a tax subsidy to physically injured tort plaintiffs who enter into structured settlements. The subsidy allows these plaintiffs to exempt the investment yield imbedded within the structured settlement from federal income taxation. The apparent purpose of the subsidy is to encourage physically injured plaintiffs to invest, rather than presently consume, their litigation recoveries. Although the statutory subsidy by its terms is available only to physically injured tort plaintiffs, a growing structured settlement industry now contends that the same tax benefit of yield exemption is available to plaintiffs’ lawyers and nonphysically injured tort plaintiffs under general, common-law tax principles. If the structured settlement industry is correct, then all tort plaintiffs and their lawyers may invest their litigation proceeds in a tax-free manner simply by using structured payment arrangements. Structured arrangements, therefore, would be far superior to traditional tax-favored retirement accounts (e.g., 401(k)s, IRAs), which provide the same tax benefit of yield exemption but are subject to significant constraints. Accordingly, if proponents of structured arrangements are correct in their interpretation of the tax law, these arrangements can be described as “super-IRAs” because they provide full yield exemption without any corresponding limitations or restrictions. This Article examines the taxation of structured payment arrangements, ultimately concluding that the structured settlement industry’s positions are unpersuasive. Nevertheless, because of the muddled state of the tax law on the issue, this Article recommends legislative and administrative action to close the yield-exemption loophole with respect to its unintended beneficiaries

Frustration Driven Stripe Domain Formation in Co/Pt Multilayer Films

We report microscopic mechanisms for an unusual magnetization reversal behavior in Co/Pt multilayers where some of the first-order reversal curves protrude outside of the major loop. Transmission x-ray microscopy reveals a fragmented stripe domain topography when the magnetic field is reversed prior to saturation, in contrast to an interconnected pattern when reversing from a saturated state. The different domain nucleation and propagation behaviors are due to unannihilated domains from the prior field sweep. These residual domains contribute to random dipole fields that impede the subsequent domain growth and prevent domains from growing as closely together as for the interconnected pattern.Comment: 13 pages, 3 figures, to appear in AP

On the existence of effective potentials in time-dependent density functional theory

We investigate the existence and properties of effective potentials in time-dependent density functional theory. We outline conditions for a general solution of the corresponding Sturm-Liouville boundary value problems. We define the set of potentials and v-representable densities, give a proof of existence of the effective potentials under certain restrictions, and show the set of v-representable densities to be independent of the interaction.Comment: 13 page

Comment on "Quantum mechanics of smeared particles"

In a recent article, Sastry has proposed a quantum mechanics of smeared particles. We show that the effects induced by the modification of the Heisenberg algebra, proposed to take into account the delocalization of a particle defined via its Compton wavelength, are important enough to be excluded experimentally.Comment: 2 page

Residual Oil Aerosol Measurements on Refridgerators and Liquefiers

The purity of the process gas is essential for the reliability of refrigerators and liquefiers. Filtration and adsorption of impurities like water, nitrogen, and oil result in a major effort, cost, and maintenance in the helium process. Expensive impurity monitors for moisture, nitrogen, and hydrocarbon contents are required to identify filter failures and leakage immediately during the operation. While water and nitrogen contaminants can be detected reliably, the measurement of oil aerosols at the ppb level is challenging. We present a novel diagnostic oil aerosol measurement system able to measure particles in the sub amp; 956;m range. This unit enabled us to evaluate and improve the oil separation system on a LINDE TCF 50 helium liquefie

Production Systems Involving Stocker Cattle and Soft Red Winter Wheat

A three year study at the Livestock and Forestry Research Station near Batesville, Arkansas evaluated production systems involving stocker cattle and soft red winter wheat. Grazing of soft red winter wheat forage from October through February followed by harvesting wheat grain or grazing through April with stocker cattle offers an alternative to conventional farming. Soft red winter wheat, when planted by September 15, produces an ample supply of high-quality forage that supports rapid growth of stocker cattle during October through April. Net income from stocker cattle averaged over $100 per acre. A normal wheat grain crop can also be harvested. These alternative production systems could increase the agricultural income by over$75,000,000 per year if 750,000 acres of wheat are grazed

Evidence for a dynamic phase transition in [Co/Pt]_3 magnetic multilayers

A dynamic phase transition (DPT) with respect to the period P of an applied alternating magnetic field has been observed previously in numerical simulations of magnetic systems. However, experimental evidence for this DPT has thus far been limited to qualitative observations of hysteresis loop collapse in studies of hysteresis loop area scaling. Here, we present significantly stronger evidence for the experimental observation of this DPT, in a [Co(4 A)/Pt(7 A)]_3-multilayer system with strong perpendicular anisotropy. We applied an out-of-plane, time-varying (sawtooth) field to the [Co/Pt]_3 multilayer, in the presence of a small additional constant field, H_b. We then measured the resulting out-of-plane magnetization time series to produce nonequilibrium phase diagrams (NEPDs) of the cycle-averaged magnetization, Q, and its variance, Var(Q), as functions of P and H_b. The experimental NEPDs are found to strongly resemble those calculated from simulations of a kinetic Ising model under analagous conditions. The similarity of the experimental and simulated NEPDs, in particular the presence of a localized peak in the variance Var(Q) in the experimental results, constitutes strong evidence for the presence of this DPT in our magnetic multilayer samples. Technical challenges related to the hysteretic nature and response time of the electromagnet used to generate the time-varying applied field precluded us from extracting meaningful critical scaling exponents from the current data. However, based on our results, we propose refinements to the experimental procedure which could potentially enable the determination of critical exponents in the future.Comment: substantial revision; 26 pages, 9 figures; to appear in Phys. Rev.

Quantum data processing and error correction

This paper investigates properties of noisy quantum information channels. We define a new quantity called {\em coherent information} which measures the amount of quantum information conveyed in the noisy channel. This quantity can never be increased by quantum information processing, and it yields a simple necessary and sufficient condition for the existence of perfect quantum error correction.Comment: LaTeX, 20 page