State Workarounds to the IRC\u27s SALT Cap: The Past, the Present, and Building for the Future

Recently, Congress has debated measures to provide some relief to taxpayers negatively impacted by the Internal Revenue Code’s State and Local Tax (SALT) deductibility limit. Although Congress has not yet budged on whether to adjust this cap, many states have taken it upon themselves to find creative workarounds to provide relief for their constituent taxpayers. In the face of an uncertain future for the current SALT cap, crucial questions exist for these state workarounds and those still to come. This Note carefully lays out the individual income tax issue posed by the SALT cap, before analyzing the core elements of each state workaround passed through March 2022. This Note then takes on each of these key elements and posits a best path forward, with an eye toward cohesively providing the most flexibility for pass-through entity owners, ultimately concluding that state workarounds present benefits for taxpayers that should propel their adoption despite any federal SALT cap uncertainty or existence

New polymer and derivative chemistry of icosahedral carboranes

This thesis describes research carried out to establish routes to, and syntheses and characterisation of aromatic poly(etherketones), with icosahedral carboranes (C(_2)B(_1)(_0)H(_1)(_2)) incorporated into the polymer backbone (poly(carboranyletherketones)). Several sidelines which have stemmed from this work are also described. A brief literature review and discussion of project objectives introduces the work. The mechanism of formation and the general characterisation of icosahedral carboranes is then discussed along with a description of various syntheses of C-carborane derivatives. Chapter 3 describes a series of model reactions performed to test the feasibility of the various routes available for the preparation of poly(carboranyletherketones). Electrophilic polyacylation in superacid solution was found to be the most convenient method. Hence monomers (suitably substituted derivatives of 1,2-diphenyl-ortho-carborane) were prepared for polymer synthesis Under these conditions. Chapter 4 outlines the preparation and characterisation of four poly(carboranyletherketones). These polymers are shown by NMR to have the expected structures. Their solution and calorimetric characteristics show the polymers to be totally amorphous, with the polymer chains being stiffened by the presence of the 1, 2-diphenyl- ortho-carborane unit. The thermal % weight loss from these polymers both in air and in nitrogen is substantially less than that shown by parent poly (etherketones).Various C-hydroxy carboranes (R(0H)C2BiqHi0) and their trialkylammonium salts have been prepared and used to examine the effects of electron delocalisation into the carborane cage. Evidence for this originally provided by I.R. data is backed up by the molecular structure of the proton sponge salt Ph(0)C(_2)B(_14)H(_10) – C(_14)H(_19)N(_2)+. This structure shows novel cage distortions which are rationalised by frontier orbital considerations. Attempts to monitor electron delocalisation into the cage using 11B NMR, have led to a detailed NMR study of a series of carborane derivatives. As a result, various substituent effects have been highlighted. These effects have been qualitatively related to the change in polarity of the cage, using MOBI calculations to estimate changes in charge distribution throughout the cage. Finally, Appendix A summarises some additional studies, carried out to determine the ways lithium interacts with boron hydride anions BH(_4)- and B(_1-)H(_10)(^2)-

Task Persistence in Early Childhood Education

This study was designed to discover developmental trends in task persistence (TP). It was hoped that the results would suggest when and for what groups a task persistence (TP) curriculum is crucial. To study this development a sample of two, four, and six year old children were given a work task. The task required 120 subjects (Ss) to sort and fold 33 items of clothing and linen. After the task instructions and demonstration, the experimenter did not intervene with reinforcers or further directions. The dependent variables investigated were time spent on the task, time spent away from the task, and number of tasks completed. The independent variables were age, race (Black and White), sex, and social class (advantaged and disadvantaged). The data were analyzed with analysis of variance, Pearson\u27s Product-Moment Correlation, and chi square. The results indicated that older children spent significantly more time on task and significantly less time away from task than younger children. Black children spent significantly more time (than White children) on and away from the task at all ages. Advantaged children spent significantly more time (than disadvantaged children) on task at all ages and significantly less time away from task at ages two and four. Advantaged and disadvantaged subjects were not differentiated by the time spent away from the task at age six. These results imply that task persistence training programs could begin as early as age two. They also suggest that certain subgroups (i.e., disadvantaged White) may require more intensive task persistence training then other subgroups (i.e., advantaged Black). Completion of tasks (CT) significantly differentiated six year olds from two and four year olds, but failed to differentiate two and four year olds. Tasks were completed significantly more often at ages two and four by males than females and by advantaged than disadvantaged children. However, these differences disappeared by age six. Since the differences faded at age six, the use of completion of tasks training as a general curriculum goal may not be warranted. Some of the most surprising results were described by the significant correlation coefficients. The total time spent on the task was negatively related to completion of task. Completion of task was positively related to the time spent away from the task and number of times away from task. These findings suggest that brief periods of absence from a task may improve the chances of completing the task. Therefore, optimal work performance for early childhood education may be realized by programming frequent, brief breaks. A secondary purpose of the study was to investigate verbalizations expressed during the experimental sessions. To study this variable, a verbatim record was established and maintained for each subject. The verbalizations were then totaled and classified as task relevant or irrelevant. The results were analyzed with an analysis of variance (age x race x sex x social class) and Pearson\u27s Product Moment Correlation. Although the number of verbalizations increased with age, the differences between ages four and six were not significant. This finding may reflect a shift to covert verbal mediation during work performance on or about age four. The developmental patterns of verbalizations were different for boys and girls. The girls used more overt verbalizations (than boys) at ages two and four; however, at age six the girls\u27 number of verbalizations decreased noticeably. The verbalizations of boys increased with age. At age six, they used more verbalizations than the girls. The writer concluded that this finding reflected advanced verbalization skills in the girls. If the conclusion is valid, the results may mean that overt verbalizations are more necessary for boys to organize their experiences. White children used significantly more task relevant verbalizations than Black children. This suggests that early childhood educational programs for predominately Black populations may need to stress task relevant verbalization training more than programs which serve predominately White populations. Disadvantaged children used more task irrelevant verbalizations at ages two and six than advantaged children. Apparently, they need extra emphasis on task oriented verbalization training. When considered with the previous paragraph, the disadvantaged Black population has the greatest need for task relevant verbalization training

Effects of sodium hydroxide solutions on the permeability of magnesium clays

Definition of the Problem - Disposal of hazardous wastes is limited to three basic methods. The waste can be chemically treated to make it less hazardous, it can be incinerated, or it can be pennanently buried in a landfill. Treatment is better from an ecological standpoint, but the cost can be prohibitive. Burial in a landfill is usually more cost efficient, but steps must be taken to insure that the waste will remain contained within the site. Current practice is to line the site with a barrier to flow. Presently both synthetic and compacted clay barriers are used. The perfonnance of clay barriers or 'liners' is in dispute when the clay is subjected to a wide variety of penneants commonly found in hazardous waste management facilities. Score of the Investigation - It has been found that flow of a concentrated NaOH solution through a magnesium clay will cause a precipitation of Mg(OH)2 within the pores of the soil. This blocks the flow and lowers the coefficient of penneability. This research is an at tempt to discover the conditions of formation and possible destruction of this precipitate.Project # G-916-03 Agreement # 14-08-0001-G-916-0

Formalizing Kant’s Rules

This paper formalizes part of the cognitive architecture that Kant develops in the Critique of Pure Reason. The central Kantian notion that we formalize is the rule. As we interpret Kant, a rule is not a declarative conditional stating what would be true if such and such conditions hold. Rather, a Kantian rule is a general procedure, represented by a conditional imperative or permissive, indicating which acts must or may be performed, given certain acts that are already being performed. These acts are not propositions; they do not have truth-values. Our formalization is related to the input/ output logics, a family of logics designed to capture relations between elements that need not have truth-values. In this paper, we introduce KL3 as a formalization of Kant’s conception of rules as conditional imperatives and permissives. We explain how it differs from standard input/output logics, geometric logic, and first-order logic, as well as how it translates natural language sentences not well captured by first-order logic. Finally, we show how the various distinctions in Kant’s much-maligned Table of Judgements emerge as the most natural way of dividing up the various types and sub-types of rule in KL3. Our analysis sheds new light on the way in which normative notions play a fundamental role in the conception of logic at the heart of Kant’s theoretical philosophy