Voluntary Payments to Widows of Corporate Executives: Gifts or Income?

The solicitude of hardhearted corporations for the widows of corporate executives has given rise to an abundance of cases involving the question whether payments to these widows constitute gifts or income. In the cases to be considered in this comment, payments are made by the corporation to the decedent\u27s widow on a purely voluntary basis. In the typical situation, the board of directors adopts a resolution eulogizing the decedent and authorizing payments to his widow in recognition of his long and faithful service. In most cases, these payments are measured by the decedent\u27s salary and continue for periods ranging from a few months to a few years. The Commissioner of Internal Revenue relies upon section 61(a) and claims that the widow\u27s receipts constitute taxable income. The widow insists that she has received a gift which may be excluded from gross income under section 102(a). Prior to the Supreme Court\u27s decision in Commissioner v. Duberstein, the Commissioner met with little success in his attempts to tax these payments. Since Duberstein, however, the courts have widely disagreed. By tracing the development of the widow payment phase of the gift-income controversy and by delineating possible solutions to the problems which presently exist, it is hoped that guidelines will be provided for remedial action by either Congress or the courts

Federal Income Tax-Deductibilty of Depreciation in Year of Sale Where Sale Price Exceeds Adjusted Basis of Asset

Plaintiff sold all the assets used in its business, in the middle of a fiscal year, at a price in excess of their depreciated cost at the beginning of the year. When plaintiff purchased the assets in question, it intended to use them until they became scrap. The assets were sold as part of a going concern years before plaintiff originally intended to dispose of them. A depreciation deduction claimed in the year of the sale was disallowed. An additional assessment was paid, a claim for refund was denied, and this suit was instituted. Held, judgment for plaintiff. Depreciation is deductible even though assets are sold during the taxable year at a price in excess of their depreciated cost at the beginning of the year. S & A Co. v. United States, 218 F. Supp. 677 (D. Minn. 1963)

Migraine, Fibromyalgia, and Depression among People with IBS: A Prevalence Study

BACKGROUND. Case descriptions suggest IBS patients are more likely to have other disorders, including migraine, fibromyalgia, and depression. We sought to examine the prevalence of these conditions in cohorts of people with and without IBS. METHODS. The source of data was a large U.S. health plan from January 1, 1996 though June 30, 2002. We identified all people with a medical claim associated with an ICD-9 code for IBS. A non-IBS cohort was a random sample of people with an ICD-9 code for routine medical care. In the cohorts, we identified all claims for migraine, depression, and fibromyalgia. We estimated the prevalence odds ratios (PORs) of each of the three conditions using the Mantel-Haenszel method. We conducted quantitative sensitivity analyses to quantify the impact of residual confounding and in differential outcome identification. RESULTS. We identified 97,593 people in the IBS cohort, and a random sample of 27,402 people to compose the non-IBS comparison cohort. With adjustment, there was a 60% higher odds in the IBS cohort of having any one of the three disorders relative to the comparison cohort (POR 1.6, 95% CI 1.5 – 1.7). There was a 40% higher odds of depression in the IBS cohort (POR 1.4, 95% CI 1.3 – 1.4). The PORs for fibromyalgia and migraine were similar (POR for fibromyalgia 1.8, 95% CI 1.7 – 1.9; POR for migraine 1.6, 95% CI 1.4 – 1.7). Differential prevalence of an unmeasured confounder, or imperfect sensitivity or specificity of outcome detection would have impacted the observed results. CONCLUSION. People in the IBS cohort had a 40% to 80% higher prevalence odds of migraine, fibromyalgia, and depression

Prop-fan with improved stability

Improved prop-fan stability is achieved by providing each blade of the prop-fan with a leading edge which, outwardly, from a location thereon at the mid-span of the blade, occupy generally a single plane

Simulating Three-Dimensional Hydrodynamics on a Cellular-Automata Machine

We demonstrate how three-dimensional fluid flow simulations can be carried out on the Cellular Automata Machine 8 (CAM-8), a special-purpose computer for cellular-automata computations. The principal algorithmic innovation is the use of a lattice-gas model with a 16-bit collision operator that is specially adapted to the machine architecture. It is shown how the collision rules can be optimized to obtain a low viscosity of the fluid. Predictions of the viscosity based on a Boltzmann approximation agree well with measurements of the viscosity made on CAM-8. Several test simulations of flows in simple geometries -- channels, pipes, and a cubic array of spheres -- are carried out. Measurements of average flux in these geometries compare well with theoretical predictions.Comment: 19 pages, REVTeX and epsf macros require

Instability of Extremal Relativistic Charged Spheres

With the question, ``Can relativistic charged spheres form extremal black holes?" in mind, we investigate the properties of such spheres from a classical point of view. The investigation is carried out numerically by integrating the Oppenheimer-Volkov equation for relativistic charged fluid spheres and finding interior Reissner-Nordstr\"om solutions for these objects. We consider both constant density and adiabatic equations of state, as well as several possible charge distributions, and examine stability by both a normal mode and an energy analysis. In all cases, the stability limit for these spheres lies between the extremal ($Q = M$) limit and the black hole limit ($R = R_+$). That is, we find that charged spheres undergo gravitational collapse before they reach $Q = M$, suggesting that extremal Reissner-Nordtr\"om black holes produced by collapse are ruled out. A general proof of this statement would support a strong form of the cosmic censorship hypothesis, excluding not only stable naked singularities, but stable extremal black holes. The numerical results also indicate that although the interior mass-energy $m(R)$ obeys the usual $m/R < 4/9$ stability limit for the Schwarzschild interior solution, the gravitational mass $M$ does not. Indeed, the stability limit approaches $R_+$ as $Q \to M$. In the Appendix we also argue that Hawking radiation will not lead to an extremal Reissner-Nordstr\"om black hole. All our results are consistent with the third law of black hole dynamics, as currently understood

Behavioral Social Work in Community and Organizational Settings

Principles and methods of behavioral social work have found little application at the community and organizational levels of intervention. It is the contention of the authors that integration of such content would enhance practice at these levels. Components of behavioral community intervention are indicated and illustrated in micro/macro settings, with advantages to practice specified. Ethical Considerations in using this methodology are discussed