Magnetomechanical effects in textured polycrystalline Tb76Dy24

Uniaxial stress-strain measurements were performed on polycrystalline Tb76Dy24 alloys which exhibit "giant magnetostriction" at cryogenic temperatures. The Young's moduli were reduced by up to a factor of five at 77 K, in comparison to their values at 300 K. We attribute this reduction to a mechanical compliance from domain rotation. Large mechanical hysteresis is also found in nominally elastic stress-strain curves measured below the Curie temperature. Hysteretic curves from 0 to 25 MPa demonstrate up to 19% dissipation of the applied mechanical energy. The anisotropy of thermal expansion was also measured and used as a parameter for the degree of crystallographic texture. This anisotropy was correlated to bulk magnetostriction and to mechanical hysteresis

Nanocrystalline and Thin Film Germanium Electrodes with High Lithium Capacity and High Rate Capabilities

Germanium nanocrystals (12 nm mean diam) and amorphous thin films (60-250 nm thick) were prepared as anodes for lithium secondary cells. Amorphous thin film electrodes prepared on planar nickel substrates showed stable capacities of 1700 mAh/g over 60 cycles. Germanium nanocrystals showed reversible gravimetric capacities of up to 1400 mAh/g with 60% capacity retention after 50 cycles. Both electrodes were found to be crystalline in the fully lithiated state. The enhanced capacity, rate capability (1000C), and cycle life of nanophase germanium over bulk crystalline germanium is attributed to the high surface area and short diffusion lengths of the active material and the absence of defects in nanophase materials

Retroactivity Revisited

In three prior articles, I considered transitional problems of changes the tax law. My general analysis and its specific application to the adoption of a consumption tax were criticized last year in this journal by Avishai Shachar. By taking liabilities explicitly into account in considering tax transition rules, Shachar extended the fundamental principles generated by my theory of legal transitions. Shachar, however, misunderstood or mischaracterized much of my earlier work. In this comment, I respond briefly to Shachar\u27s criticisms. In Part I, I set out the context and conclusions of my general theory and suggest that Shachar agrees with its principal insights. In Part II, I show that, although Shachar correctly suggests that a comprehensive analysis of transitional rules must take liabilities into account, his central analytical premise – that [e]ach increase in the price of an asset has an equal and offsetting impact on the \u27burden\u27 of a liability – is surely wrong. I also demonstrate in that Part several difficulties with Shachar\u27s general approach to transitional problems. Finally, in Part I, I comment briefly on his specific recommendations for transition to a consumption tax

The 1982 Minimum Tax Amendment as a First Step in the Transition to a "Flat-Rate" Tax

The massive body of tax legislation enacted in the first two years of the Reagan Administration offers little guidance for predicting the future direction of United States tax policy. Dramatically different Congressional coalitions—each led by the President—passed by very narrow margins the nation's largest tax reduction (the Economic Recovery Tax Act of 1981) and then the next year enacted the largest peacetime tax increase (the Tax Equity and Fiscal Responsibility Act of 1982). In each case, short-term political and fiscal concerns dominated the debates. The 1981 legislation reduced taxes in an effort to stimulate economic activity and investment by according substantial tax relief to businesses and high income individuals; the 1982 legislation requires significant additional taxes from these same sources to reduce triple-digit deficits, a reduction also deemed necessary for economic recovery. Although the two Acts together provide for an overall reduction in business taxes and a phased-in decrease in marginal tax rates applicable to individuals, they impart the overwhelming impression that uncertainty, confusion, and inconsistency currently dominate the tax legislative process

The David R. Tillinghast Lecture: Taxing International Income: Inadequate Principles, Outdated Concepts, and Unsatisfactory Policies

It is a pleasure to be here today to deliver the first David R. Tillinghast Lecture of the 21st century, a lecture honoring a man who has done much to shape and stimulate our thinking about the international tax world of the 20th. Our nation\u27s system for taxing international income today is largely a creature of the period 1918-1928, a time when the income tax was itself in childhood. From the inception of the income tax (1913 for individuals, 1909 for corporations) until 1918, foreign taxes were deducted like any other business expense. In 1918, the foreign tax credit (FTC) was enacted. This unilateral decision by the United States to allow taxes paid abroad to reduce U.S. tax liability dollar for dollar – taken principally to redress the unfairness of double taxation of foreign source income – was extraordinarily generous to those nations where U.S. companies earned income. In contrast, Britain, also a large capital exporter, until the 1940\u27s credited only foreign taxes paid within the British Empire and limited its credit to a maximum of one-half the British taxes on the foreign income. In 1921, Congress limited the foreign tax credit to ensure that a taxpayer\u27s total foreign tax credits could not exceed the amount of U.S. tax liability on the taxpayer\u27s foreign source income. This limitation was enacted to prevent taxes from countries with higher rates from reducing U.S. tax liability on U.S. source income

Retroactivity Revisited

In three prior articles, I considered transitional problems of changes the tax law. My general analysis and its specific application to the adoption of a consumption tax were criticized last year in this journal by Avishai Shachar. By taking liabilities explicitly into account in considering tax transition rules, Shachar extended the fundamental principles generated by my theory of legal transitions. Shachar, however, misunderstood or mischaracterized much of my earlier work. In this comment, I respond briefly to Shachar\u27s criticisms. In Part I, I set out the context and conclusions of my general theory and suggest that Shachar agrees with its principal insights. In Part II, I show that, although Shachar correctly suggests that a comprehensive analysis of transitional rules must take liabilities into account, his central analytical premise—that [e]ach increase in the price of an asset has an equal and offsetting impact on the \u27burden\u27 of a liability —is surely wrong. I also demonstrate in that Part several difficulties with Shachar\u27s general approach to transitional problems. Finally, in Part III, I comment briefly on his specific recommendations for transition to a consumption tax

The Truth-in-Negotiations Act - An Examination of Defective Pricing in Government Contracts

Charges of excessive profitmaking on government contracts have issued from the Senate floor and the nation\u27s press and have provided the impetus for recent congressional investigations and proposals for remedial legislation. Profiteering by government contractors is a problem of potentially enormous dimensions since purchases by the federal government total more than seventy-seven billion dollars—over ten per cent of the gross national product. Because the greatest part of these purchases are made by the Department of Defense, congressional action aimed at minimizing excessive profits has focused upon Defense Department procurement activities under the Armed Services Procurement Act (ASPA)