Maybe Just a Little Bit Special, After All?

The attitude—common among tax professionals—that tax is special (mostly because of its supposedly unique complexity), and that special legal rules should apply in the tax context, has been described and excoriated by scholars as tax exceptionalism or tax myopia. The Supreme Court dealt tax exceptionalism a grievous blow in its 2011 opinion in Mayo Foundation for Medical Education & Research v. United States, in which it held that the Chevron standard for determining the validity of regulations applied in tax just as it applied in other fields. One commentator gleefully celebrated Mayo as the death knell of tax exceptionalism, declaring, The tax world finally recognized a stark fact of life in 2011: Tax law is not special. This Article offers, with numerous hedges and qualifications, a defense of the exceptionalists and of exceptionalism. It makes three points for the defense. First, it is not so much tax professionals who think tax is special; rather, the view of tax as a thing apart is held most strongly by everyone else. Second, to the extent tax professionals do believe that tax is special, they resemble antitrust lawyers who think that antitrust is special, bankruptcy lawyers who think that bankruptcy is special, and so on. In other words, there is nothing exceptional about tax exceptionalism. And, finally, to the extent tax professionals not only think tax is special but also think it is more special than, say, antitrust lawyers think that antitrust is special, they may not be altogether wrong. Maybe tax really is just a little bit special, after all

Tin clustering and precipitation in the oxide during autoclave corrosion of Zircaloy-2

Atom probe tomography has been used to study the evolution of tin distribution during the corrosion process in Zircaloy-2. From being completely soluble in the Zr metal matrix, some clustering is evident already in the newly formed oxide close to the metal-oxide interface. Analysis of thicker oxides a few hundred nanometers away from the interface reveals fully developed precipitates of metallic Sn particles of up to 20 nm in size. Although the precipitates contain significant amounts of Zr, it is concluded that they are in the process of being depleted in Zr, which is limited only by the slow diffusion in the oxide scale. The findings are interpreted as being a result of the nobility of the Sn yielding a strong driving force to remain in a metallic state after incorporation in the barrier oxide layer. As Sn occupies substitutional sites in the ZrO2 lattice it is oxidized to a 4+ state when incorporated into the oxide, and in order to remain metallic it must nucleate into precipitates within the inner part of the oxide scale before being re-oxidized to 2+ and eventually to 4+ when the oxygen activity is sufficiently high in the outer parts of the oxide

Complete precipitate dissolution during adiabatic shear localisation in a Ni-based superalloy

Whereas microstructure evolution in adiabatic shear bands have been thoroughly studied, reports on the stability of hardening precipitates during shear localisation are scarce. We report an atomic scale investigation of solute distribution in adiabatic shear bands in a precipitation strengthened Ni-Fe-based superalloy, showing that the hardening particles are completely dissolved. Temperature estimations indicate that peak temperatures in the shear band above the solvus limits of the precipitates are not unrealistic, and thus diffusion-assisted transformations during the severe plastic deformation cannot be ruled out

Formation of corrosion pockets in FeNiCrAl at high temperatures investigated by 3D FIB-SEM tomography

A recently published study of high temperature nitridation of iron chromium aluminum alloys (FeCrAl) at 900 degrees C in N-2-H(2)has redundantly shown the formation of locally confined corrosion pockets reaching several microns into the alloy. These nitrided pockets form underneath chromia islands laterally surrounded by the otherwise protective alumina scale. Chromia renders a nitrogen-permeable defect under the given conditions and the presence of aluminum in the alloy. In light of these findings on FeCrAl, a focused ion beam-scanning electron microscope tomography study has been undertaken on an equally nitrided FeNiCrAl sample to characterize its nitridation corrosion features chemically and morphologically. The alloy is strengthened by a high number of chromium carbide precipitates, which are also preferential chromia formation sites. Besides the confirmation of the complete encapsulation of the corrosion pocket from the alloy by a closed and dense aluminum nitride rim, very large voids have been found in the said pockets. Furthermore, metallic particles comprising nickel and iron are deposited on top of the outer oxide scale above such void regions

The distribution of O and N in the surface region of laser-patterned titanium revealed by atom probe tomography

Direct Laser Interference Lithography (DLIL) has shown to be a promising technique to chemically and physically alter the surface of titanium. In this work, atom probe tomography analysis was performed on DLIL-treated titanium to obtain the chemical composition of the surface in maxima and minima interference positions. The analysis revealed that a multilayer structure consisting of oxide/oxynitride is formed at both positions; however, the chemical composition is altered differently between the two. The observed difference is believed to be due to an uneven heating and temperature distribution, which is demonstrated by thermal simulations

An atom probe tomography study of the chemistry of radiation-induced dislocation loops in Zircaloy-2 exposed to boiling water reactor operation

This study is complementary to previous atom probe tomography (APT) studies of irradiation effects in the zirconium alloy Zircaloy-2. Using APT in voltage pulse mode, a difference in morphology was observed between clusters of Fe and Ni and clusters of Fe and Cr in Zircaloy-2 exposed to a high fast neutron fluence in a commercial boiling water reactor. The Fe–Ni clusters were disc-shaped with a diameter of 5–15 nm, whereas the Fe–Cr clusters were spheroidal with a diameter of approximately 5 nm. Both types of clusters appeared to be located at irradiation-induced <a>-type dislocation loops aligned in layers normal to the <c>-direction. The concentration of Fe was higher in the Fe–Cr clusters than in the Fe–Ni clusters. The dilute Fe–Ni clusters, which seem to be segregation of Fe and Ni inside the loops, had formed on all three families of first-order prismatic planes with some deviation from perfect <c>-axis alignment. The Fe–Cr clusters might be very small precipitates with a nucleation associated with the loops

Nanoscale chemistry of Zircaloy-2 exposed to three and nine annual cycles of boiling water reactor operation — an atom probe tomography study

Atom probe tomography was used in this work to study the metal close to the metal/oxide interface in the zirconium alloy Zircaloy-2 exposed to three and nine annual cycles of operation in a commercial boiling water reactor. The two exposure times correspond to before and after the onset of acceleration in corrosion, hydrogen pickup, and growth. The alloying elements Sn, Fe, Cr, and Ni were observed to be redistributed after exposure. After both three and nine cycles, clusters containing Fe and Cr and typically of a spheroidal shape with an approximate diameter of 5 nm were observed to be located in layers presumed to be layers of -loops. On average, the cluster number density was slightly higher after nine cycles, with larger and more Cr-rich clusters. However, there were large grain-to-grain variations, which were larger than the differences between the two exposure times. Ni was only occasionally observed in the clusters. Sn was observed to be slightly enriched in the Fe–Cr clusters, but the Sn concentration was higher between than inside the layers of clusters. After nine cycles, clusters of Sn were detected in regions that were depleted of Fe and Cr. Enrichment of Sn, Fe, and Ni at features that appeared to be -component loops was observed after nine cycles, whereas no such features were observed after three cycles. Enrichment of Sn and Fe, and small amounts of Cr and Ni, was observed at grain boundaries after both exposure times. After three cycles, a partially dissolved second phase particle of Zr(Fe,Cr)2 type that contained about ten times more Cr than Fe was observed

Redistribution of alloying elements in Zircaloy-2 after in-reactor exposure

An atom probe tomography study of the microstructure of a Zircaloy-2 material subjected to 9 annual cycles of BWR exposure has been conducted. Upon dissolution of secondary phase particles, Fe and Cr are seen to reprecipitate in large numbers of clusters and particles of 1-5 nm sizes throughout the Zr metal matrix. Fe and Sn were observed to segregate to ring-shaped features in the metal that are interpreted to be <c>-component vacancy loops. This implies that these two elements play a major role in the irradiation growth phenomenon in Zr alloys, which is believed to be caused by the formation of <c>-loops. Similarly to autoclave-corroded Zr alloys, the formation of a sub-oxide layer of approximate composition ZrO was observed. On the other hand, no oxygen saturated metal phase was detected underneath the oxide scale

Nano-scale characterization of white layer in broached Inconel 718

The formation mechanism of white layers during broaching and their mechanical properties are not well investigated and understood to date. In the present study, multiple advanced characterization techniques with nano-scale resolution, including transmission electron microscopy (TEM), transmission Kikuchi diffraction (TKD), atom probe tomography (APT) as well as nano-indentation, have been used to systematically examine the microstructural evolution and corresponding mechanical properties of a surface white layer formed when broaching the nickel-based superalloy Inconel 718. TEM observations showed that the broached white layer consists of nano-sized grains, mostly in the range of 20–50 nm. The crystallographic texture detected by TKD further revealed that the refined microstructure is primarily caused by strong shear deformation. Co-located Al-rich and Nb-rich fine clusters have been identified by APT, which are most likely to be γ′ and γ′′ clusters in a form of co-precipitates, where the clusters showed elongated and aligned appearance associated with the severe shearing history. The microstructural characteristics and crystallography of the broached white layer suggest that it was essentially formed by adiabatic shear localization in which the dominant metallurgical process is rotational dynamic recrystallization based on mechanically-driven subgrain rotations. The grain refinement within the white layer led to an increase of the surface nano-hardness by 14% and a reduction in elastic modulus by nearly 10% compared to that of the bulk material. This is primarily due to the greatly increased volume fraction of grain boundaries, when the grain size was reduced down to the nanoscale

The Effect of Iron on Dislocation Evolution in Model and Commercial Zirconium Alloys

Although the evolution of irradiation-induced dislocation loops has been well correlated with irradiation-induced growth phenomena, the effect of alloying elements on this evolution remains elusive, especially at low fluences. To develop a more mechanistic understanding of the role iron has on loop formation, we used state-of-the-art techniques to study a proton-irradiated Zr-0.1Fe alloy and proton- and neutron-irradiated Zircaloy-2. The two alloys were irradiated with 2-MeV protons up to 7 dpa at 350\ub0C and Zircaloy-2 up to 14.7 7 1025n • m-2, approximately 24 dpa, in a boiling water reactor at approximately 300\ub0C. Baseline transmission electron microscopy showed that the Zr3Fe secondary-phase particles in the binary system were larger and fewer in number than the Zr (Fe, Cr)2and Zr2(Fe, Ni) particles in Zircaloy-2. An analysis of the irradiated binary alloy revealed only limited dissolution of Ze3Fe, suggesting little dispersion of iron into the matrix, while at the same time a higher 〈a〉-loop density was observed compared with Zircaloy-2 at equivalent proton dose levels. We also found that the redistribution of iron during irradiation led to the formation of iron nanoclusters. A delay in the onset of 〈c〉-loop nucleation in proton-irradiated Zircaloy-2 compared with the binary alloy was observed. The effect of iron redistributed from secondary-phase particles because of dissolution on the density and morphology of 〈a〉 and 〈c〉 loops is described. The implication this may have on irradiation-induced growth of zirconium fuel cladding is also discussed