TAXATION - FEDERAL GIFT TAX - INTEGRATION WITH INCOME TAX

Beck in 1935 created an irrevocable funded insurance trust of $172,000 in securities together with seven policies of insurance on his life. The income from the securities was to be applied to pay the premiums on the policies and any surplus was to be distributed to his wife and daughter. At grantor\u27s death the proceeds of the policies were to be added to the corpus of the trust and all income was to go to the same beneficiaries for life with remainders over. There was no possibility of reverter in the grantor and no right to alter, modify or revoke the trust in any way, except to substitute a different trustee. Nor did the grantor reserve any power over the policies. In his gift tax return for 1935, Beck reported the value of the securities and of the policies and deducted therefrom$48,026.65, the capitalized value of the income necessary to pay the insurance premiums during his life expectancy. He argued that he was required to include that much of the trust income in his taxable income and that it would be inconsistent to tax the same payments as income and as a gift and therefore Congress must have intended to exempt this portion from the gift tax. The Commissioner of Internal Revenue found a deficiency in the gift tax, but the Board of Tax Appeals expunged it. Held, reversing the Board of Tax Appeals, the entire corpus of the trust is subject to gift tax. There was no Congressional intent completely to integrate the gift, estate, and income taxes. The same transaction may be a completed gift for one purpose and incomplete for another. Commissioner v. Beck\u27s Estate, (C. C. A. 2d, 1942) 129 F. (2d) 243

ABSTRACTS

The abstracts consist merely of summaries of the facts and holdings of recent cases and are distinguished from the notes by the absence of discussion

ABSTRACTS

The abstracts consist merely of summaries of the facts and holdings of recent cases and are distinguished from the notes by the absence of discussion

ABSTRACTS

The abstracts consist merely of summaries of the facts and holdings of recent cases and are distinguished from the notes by the absence of discussion

ABSTRACTS

The abstracts consist merely of summaries of the facts and holdings of recent cases and are distinguished from the notes by the absence of discussion

ABSTRACTS

The abstracts consist merely of summaries of the facts and holdings of recent cases and are distinguished from the notes by the absence of discussion

History of Negotiations and Politics of Strategic Arms Limitation Talks (SALT)

This paper examines the United States\u27 negotiation strategy in the First Strategic Arms Limitation Talks. It uses a framework that combines Graham and Allison\u27s bureaucratic politics model; negotiation theory articulated by Thompson; and a modified version of two level games as articulated by Knopf. This paper argues that these three frameworks reveal that the SALT negotiations required President Nixon to satisfy five different negotiating partners: the American bureaucracy, Congress, the American public, America\u27s NATO Allies, and the Soviet Union. One must consider all of these five groups to avoid viewing American negotiating positions like the decision to offer to reduce their Best Alternative to a Negotiated Agreement (BATNA), the decision to not come up with a clear negotiating objective and the decision to deny the opportunity to expand the pie by including medium range nuclear weapons as irrational

Development of nonorthogonal wavefunction theories and application to multistate reaction processes.

Many prominent areas of technological development rely on exploiting the photochemical response of molecules. An application of particular interest is the control of molecular switches through a combination of different external stimuli. However, despite significant advances in theoretical approaches and numerous cases of successful application of theory, simulating photochemical reactions remains a computational challenge. Theoretical methods for describing excited states can be broadly divided into single-reference response methods and multireference methods. Single reference methods provide reliable semiquantitative results for single excitations. However, these methods cannot describe double-excited states, systems with strongly correlated ground states, or regions of degeneracy on the potential energy surface. The alternative, multireference methods, can provide more accurate results. However, multireference methods require significant technical and chemical insight and become computationally costly as the system size increases. I will discuss my work applying newly developed and well-known methods for understanding multistate processes. I will highlight the limitations and extent of current methodologies that prevent researchers from studying larger and more complex systems. I will also discuss new methodological developments using spin projection, which seeks to overcome several problems of single reference excited state models. I will illustrate the motivation and its performance compared to more established theories. Despite its success, the new method cannot account for ‘multiple correlation mechanisms’. As a result, I will introduce how multiple correlation mechanisms can be exploited to perform nonorthogonal active space decomposition, along with applications and paths for future improvements

Contemporary Commercial Music Pedagogy: Selective Exercises for Developing Healthy Technique in Adolescent Singers

In the developing world of vocal science there are still varying opinions on proper vocal techniques. The classical tradition has been developing for many centuries, however, the area of contemporary commercial music is still in its relative infancy by comparison. Contemporary commercial music, or CCM, refers to all other genres that are non-classical in nature, for example: musical theater, jazz, pop, country, folk, rock, and gospel. Many undergraduate vocal education programs are not addressing the pedagogical differences in approaches for CCM technique as compared to classical. This is causing educators, such as myself, to have no information about how to properly teach these techniques within the ever-growing non-traditional ensembles that are becoming more and more a part of choral programs around the country. The purpose of this thesis is to develop a set of vocal exercises that can be used for adolescent singers to develop a healthy technique within CCM styles, mainly focusing on `belt\u27 singing. This study used a qualitative approach that involved participation of four area high school choral directors, two current undergraduate vocal students, and one experienced vocal pedagogue. The investigation of current practices was done through interviews and observations of all participants, as well as through available literature on the subject matter. The three main research questions that guided this process were based on understanding the differences in pedagogical approaches between classical and CCM music, as well as my own misunderstandings of `belt\u27 voice: Main differences between CCM and classical pedagogy, what the `belt\u27 voice is and how it is used in CCM music, and what exercises can be used with adolescents to develop a healthy CCM technique. Triangulation of the data helped to show that misconceptions and misinformation is guiding teachers in educating their students. The four teachers observed and interviewed, even though very knowledgeable in the area of classical vocal use, lacked a complete understanding of how to work with adolescent voices in the area of CCM