Packaging techniques for low-altitude Venus balloons beacon

The results of a specific design project for the Venus balloon beacon, in which a microwave beacon is required to operate for a limited time at high temperature (350 C) and at high pressure, (10 bars). In a chemically hostile environment after surviving large mechanical shock forces (up to 280 gs) are discussed. It was found that many existing, commerically-available component can be used in such a design with only minor modifications. A further result is that a crude (and consequently low-cost) test program can be designed to identify and select promising commercial components

Policy and Theoretical Dimensions of Qualified Tax Partnerships

This is the published version

The Like-Kind Exchange Equity Conundrum

The tax-free treatment oflike-kind exchanges presents one of tax law’s most compelling equity conundrums. Tax law generally does not tax property holders on the property’s appreciation but does tax gain or loss recognized by property sellers and exchangers of non-like-kind property. In the basic Aristotelian system, equity requires that likes be treated alike, but the system does not provide criteria to determine what is alike. Depending upon the criteria, exchangers of like-kind property can be similar either to holders or to sellers and exchangers of non-like-kind property. The equity conundrum asks whether tax law should treat exchangers of like-kind property either the same as holders of property or the same as sellers and exchangers of non-like-kind property. This Article frames the conundrum in Rawlsian and Hohfeldian concepts. This framing suggests first that holders should not be taxed on property’s appreciation. Second, this framing explains that once tax law exempts holders’ appreciation from taxation, equity requires that exchanges of like-kind property should also be exempt from taxation. Thus, equity suggests that the tax law should treat exchangers of like-kind property and property holders similarly