State Constitutional Law Steps Out of the Shadows: Transcript of Selected Symposium Panel Discussions

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Addressing Imperfections in the Tax System: Procedural or Substantive Reform?

Books about tax administration tend to fall into one of two broad categories: those that paint the Internal Revenue Service ( IRS ) as an agency peopled by corrupt, out-of-control bureaucrats who take pleasure in seeing innocent taxpayers suffer, and those that tell readers how to structure their affairs to minimize the risk of incurring an IRS employee\u27s wrath during a tax audit. Perfectly Legal, the full title of which communicates David Cay Johnston\u27s intent to focus on the tax system, does neither of those things. Instead, it is a book much like The Great American Tax Dodge, which explained the many varieties of tax fraud; the difficulties the IRS faces in pursuing high income individuals; the influence the affluent have on lawmaking; and Congress\u27s success in tying the hands of the IRS. In its strongest chapters, Perfectly Legal examines the inner workings of the IRS and describes the agency in a very different way from that represented in the popular press. While other authors may decry the threat of overzealous IRS agents, Johnston laments the inability of IRS employees to pursue known acts of noncompliance because of resource limitations and political pressures. While other authors may complain about the complexity of the Internal Revenue Code, leaving readers with the impression that the IRS is responsible for its enactment, Johnston lays blame for this complexity squarely where it belongs - with Congress and executive branch policymakers

Tax Controversies: Practice and Procedure, 4th

This casebook teaches the mechanics of tax procedure, while stimulating students to think about the broader issues that underlie its structural framework. Tax Controversies: Practice and Procedure begins with an overview of civil tax procedure and an in-depth discussion of the federal tax gap and the many approaches to closing it. Several of the next chapters focus on stages in the chronology of a typical tax controversy, from examination through eventual litigation. Two chapters focus on tax research and representing tax clients, and another chapter addresses ethics issues in tax cases. An underlying theme—the extent to which the current procedural rules encourage or discourage voluntary compliance with the federal tax system—runs throughout the book. • Suitable for J.D. or LL.M. students, or for use in a tax clinic. • Each casebook chapter includes theory questions and a set of fact-based problems to encourage strategic thinking. Several chapters include optional drafting problems. • Teacher’s Manual provides detailed answers to the problem sets, suggests approaches to the material, and highlights topics more suitable for an advanced course. • This edition is thoroughly updated to reflect developments in the law since the previous edition. • Separate Documents Volume, Tax Controversies: Statutes, Regulations, and Other Materials, is also available.https://www.repository.law.indiana.edu/facbooks/1187/thumbnail.jp

Addressing Imperfections in the Tax System: Procedural or Substantive Reform?

In his book Perfectly Legal: The Covert Campaign to Rig Our Tax System to Benefit the Super Rich - and Cheat Everybody Else , David Cay Johnston, the Pulitzer Prize-winning reporter for the New York Times, covers a wide array of topics, including some that are quite complex, in a very readable way. The federal income tax system generally and tax compliance in particular are important focuses of the book, but the theme that implicitly connects chapters that otherwise appear unrelated is a variety of aspects of income inequality. Although Perfectly Legal does not make a clear case that politicians and others have combined in a covert campaign, it is nonetheless an engaging book containing many interesting stories. Some of its best chapters provide revealing insights into the inner workings of the IRS. The important effects that procedural rules can have on enforcement of the tax laws suggests that any comprehensive effort at tax simplification should address procedural complexity

The Revolutionary 2012 Kansas Tax Act

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Measurement of inclusive jet and dijet cross-sections in proton-proton collisions at s √ =13 TeV with the ATLAS detector

Inclusive jet and dijet cross-sections are measured in proton-proton collisions at a centre-of-mass energy of 13 TeV. The measurement uses a dataset with an integrated luminosity of 3.2 fb−1 recorded in 2015 with the ATLAS detector at the Large Hadron Collider. Jets are identified using the anti-kt algorithm with a radius parameter value of R = 0.4. The inclusive jet cross-sections are measured double-differentially as a function of the jet transverse momentum, covering the range from 100 GeV to 3.5 TeV, and the absolute jet rapidity up to |y| = 3. The double-differential dijet production cross-sections are presented as a function of the dijet mass, covering the range from 300 GeV to 9 TeV, and the half absolute rapidity separation between the two leading jets within |y| < 3, y∗, up to y∗ = 3. Next-to-leading-order, and next-to-next-to-leading-order for the inclusive jet measurement, perturbative QCD calculations corrected for non-perturbative and electroweak effects are compared to the measured cross-sections

Optimasi Portofolio Resiko Menggunakan Model Markowitz MVO Dikaitkan dengan Keterbatasan Manusia dalam Memprediksi Masa Depan dalam Perspektif Al-Qur`an

Risk portfolio on modern finance has become increasingly technical, requiring the use of sophisticated mathematical tools in both research and practice. Since companies cannot insure themselves completely against risk, as human incompetence in predicting the future precisely that written in Al-Quran surah Luqman verse 34, they have to manage it to yield an optimal portfolio. The objective here is to minimize the variance among all portfolios, or alternatively, to maximize expected return among all portfolios that has at least a certain expected return. Furthermore, this study focuses on optimizing risk portfolio so called Markowitz MVO (Mean-Variance Optimization). Some theoretical frameworks for analysis are arithmetic mean, geometric mean, variance, covariance, linear programming, and quadratic programming. Moreover, finding a minimum variance portfolio produces a convex quadratic programming, that is minimizing the objective function ðð¥with constraintsð ð 𥠥 ðandð´ð¥ = ð. The outcome of this research is the solution of optimal risk portofolio in some investments that could be finished smoothly using MATLAB R2007b software together with its graphic analysis

Rationale, study design, and analysis plan of the Alveolar Recruitment for ARDS Trial (ART): Study protocol for a randomized controlled trial

Background: Acute respiratory distress syndrome (ARDS) is associated with high in-hospital mortality. Alveolar recruitment followed by ventilation at optimal titrated PEEP may reduce ventilator-induced lung injury and improve oxygenation in patients with ARDS, but the effects on mortality and other clinical outcomes remain unknown. This article reports the rationale, study design, and analysis plan of the Alveolar Recruitment for ARDS Trial (ART). Methods/Design: ART is a pragmatic, multicenter, randomized (concealed), controlled trial, which aims to determine if maximum stepwise alveolar recruitment associated with PEEP titration is able to increase 28-day survival in patients with ARDS compared to conventional treatment (ARDSNet strategy). We will enroll adult patients with ARDS of less than 72 h duration. The intervention group will receive an alveolar recruitment maneuver, with stepwise increases of PEEP achieving 45 cmH(2)O and peak pressure of 60 cmH2O, followed by ventilation with optimal PEEP titrated according to the static compliance of the respiratory system. In the control group, mechanical ventilation will follow a conventional protocol (ARDSNet). In both groups, we will use controlled volume mode with low tidal volumes (4 to 6 mL/kg of predicted body weight) and targeting plateau pressure &lt;= 30 cmH2O. The primary outcome is 28-day survival, and the secondary outcomes are: length of ICU stay; length of hospital stay; pneumothorax requiring chest tube during first 7 days; barotrauma during first 7 days; mechanical ventilation-free days from days 1 to 28; ICU, in-hospital, and 6-month survival. ART is an event-guided trial planned to last until 520 events (deaths within 28 days) are observed. These events allow detection of a hazard ratio of 0.75, with 90% power and two-tailed type I error of 5%. All analysis will follow the intention-to-treat principle. Discussion: If the ART strategy with maximum recruitment and PEEP titration improves 28-day survival, this will represent a notable advance to the care of ARDS patients. Conversely, if the ART strategy is similar or inferior to the current evidence-based strategy (ARDSNet), this should also change current practice as many institutions routinely employ recruitment maneuvers and set PEEP levels according to some titration method.Hospital do Coracao (HCor) as part of the Program 'Hospitais de Excelencia a Servico do SUS (PROADI-SUS)'Brazilian Ministry of Healt