\u3cem\u3eMoore v. United States\u3c/em\u3e, Brief for the American Tax Policy Institute as Amicus Curiae in Support of Respondent

Petitioners’ case is not about realization, notwithstanding their claim that it “squarely and cleanly” raises that issue. The income taxed by the mandatory repatriation tax (MRT) was, in fact, realized by an Indian limited liability company (KisanKraft) while petitioners owned a stake in it. So the question here is not whether there was realized income, but who can be taxed on it. The Court has long recognized the constitutional power of Congress to tax the owners of an entity on income realized by that entity. Just as Congress has the power to tax a partner on the income earned by a partnership, Congress has the authority to tax U.S. shareholders on their share of income realized by a foreign corporation. Upholding the MRT as a tax imposed on realized income of the foreign corporation will fully dispose of the case, without taking on complicated questions like whether realization is always constitutionally required and what comprises realization. By contrast, finding that the MRT violates a constitutional shareholder-level realization requirement could be profoundly destabilizing: there will be a flood of litigation about the constitutionality of a host of other provisions

The Ursinus Weekly, October 21, 1957

Presbyterian Society honors Dr. Armstrong • MSGA meeting; Complaints heard • Student teachers begin assignments Tues., Oct. 8 • SWC seminars on religions of world • Sputnik theme of soph dance • Dance, Ruby editors subject of junior meeting • Sig Nu holds luncheon • Omega Chi homecoming • \u2757 Homecoming bring grads back to Ursinus: Gayle Livingston \u2757 queen; Walker trophy to Famous • Infirmary busy as Ursinians battle flu infection • Faith healing discussion • Editorial: Medical staff salute • Was ist das? • About sophomore psychology • Ridiculing the fad • Letters to the editor • Speedball • Peterson named to All-East team for outstanding work • Rutgers nip UC; Booters beat grads in annual game • Famous receives Walker trophy at Wilkes game • First defeat for Ursinus as Colonels tame Bears 39 to 0 • Job opportunities announced by the Placement Bureau • KDK Homecoming banquet • Delta Pi Sigma banquethttps://digitalcommons.ursinus.edu/weekly/1391/thumbnail.jp

The Ursinus Weekly, February 24, 1958

Martin Zippin to speak at Y seminar on art, Feb. 26 • Grundy crowned; Whitians named at annual Lorelei • Army med service topic at pre-med meeting tonite • Seniors present Gold in the hills March 7 and 8 • Campus Chest \u2758 charities • Ursinus photo enthusiast shows camera art in UC Library foyer • Freshman women get colors at ceremonies • Cub & Key Society requests outlines from junior men • WSGA names May queen - J. Martin; Molitor, manager • Tau Sig and Sig Rho dance held Saturday night • Editorial: Art and the student • Nothing new under Ur sun (us) • Ode to idiots • Letters to the editor • Ursinus wrestlers visit Wilkes for meet, Fri. and Sat. • Swimming and basketball finds belles victorious • U.C. cagers downed again; PMC & Swarthmore victors • Matmen trounce PMC; Record now 5 wins, one loss • Sophomores elect Drummond and Watson to MSGAhttps://digitalcommons.ursinus.edu/weekly/1400/thumbnail.jp

Limits on the Boron Isotopic Ratio in HD 76932

Data in the 2090 A B region of HD 76932 have been obtained at high S/N using the HST GHRS echelle at a resolution of 90,000. This wavelength region has been previously identified as a likely candidate for observing the B11/B10 isotopic splitting. The observations do not match a calculated line profile extremely well at any abundance for any isotopic ratio. If the B abundance previously determined from observations at 2500 A is assumed, the calculated line profile is too weak, indicating a possible blending line. Assuming that the absorption at 2090 A is entirely due to boron, the best-fit total B abundance is higher than but consistent with that obtained at 2500 A, and the best-fit isotopic ratio (B11/B10) is in the range ~10:1 to ~4:1. If the absorption is not entirely due to B and there is an unknown blend, the best-fit isotopic ratio may be closer to 1:1. Future observations of a similar metal-poor star known to have unusually low B should allow us to distinguish between these two possibilities. The constraints that can be placed on the isotopic ratio based on comparisons with similar observations of HD 102870 and HD 61421 (Procyon) are also discussed.Comment: Accepted for Nov 1998 Ap

The Ursinus Weekly, January 20, 1958

Polishuk explains space satellite, jets and rockets • Satchmo to play at Villanova, Feb. 9 • Junior pre-meds to take test May 3 • Work camps in Philadelphia • Final fling well attended • Faculty entertain at fireside chats • Foreign films featured by Philadelphia society • Ursinus Forum announces Spring semester speakers • Ursinus receives grant from du Pont • Chi Alpha to hear talk on Paul Tillich; Schedules discussion of Sartre work • Editorial: Fuel will brighten the Lantern • Power of love • Campus stickouts • Bumble puppy: A new game • UC varsity & JV hoopers bow to Blue Hens, PMC • UC red and black league intramural games begin • UC matmen win 2nd, 3rd as Garnels and Lions fall • Adam and Evesdroppinghttps://digitalcommons.ursinus.edu/weekly/1398/thumbnail.jp

The Ursinus Weekly, January 13, 1958

Faculty, students get together for fireside chats • European views of Americans told at IRC meeting • Lantern contest offers prizes to writers and artists • Satellites topic at chem meeting tonight in S-12 • Library receives 400 dollar grant • Lorelei discussed, proctors named at MSGA meeting • Student teachers\u27 tales amuse SEAP meeting • Picasso exhibition opens at Philadelphia art museum • Tranquilizers subject of pre-med meeting, Jan. 8 • Podolak captains color guard • Sig Nu & Delta Pi to hold final fling January 18 • Editorial: It\u27s our move now • Trim the wick and brighten the Lantern • Prize poems • Picasso: Biography • Valentine Day opener set for girls\u27 badminton team • Girls\u27 basketball opener set for Feb. 12 with G\u27burg • UC grapplers beat Haverford 19-13 in season\u27s opener • Varsity cagers lose; J.V.s beat Swarthmore, Haverford • Bears scalped by Indians 81-69 in year-end game • Beta Sig mardi gras held • Frosh give dance: Beneath the sea • Many fields included in new library accessionshttps://digitalcommons.ursinus.edu/weekly/1397/thumbnail.jp

The Ursinus Weekly, March 10, 1958

Spray of Springtime theme of the junior prom, Mar. 21 • Group production of French farce now in rehearsal • Fireside chats and art forum on Y agenda for March • IFC weekend, Apr. 25-26; Dances, picnic planned • Roland\u27s rendezvous theme of soph hop, Sat. • Band members at festival • Council reviews rules; Revises judiciary powers • Fraternities bid men today at noon • Selective Service department test applications due • Ursinus alumni to hold a dinner dance, March 22 • Curtain Club to present famous art historian tomorrow, Mar. 11 • Final week of Campus Chest drive; Goal $1500 • 105 on Dean\u27s list for Fall semester • Gold in the hills adds to 1958 Ruby coffers • Editorial: Give once for all • Letters to the editor • Review: Gold in the hills • Time has come • Off the cuff fashions for men • \u2758 basketball season roundup shows 1 win • Badminton belles win two games • Belles down Beaver 56-50 for third win in a row • U.C. dunks Drexel; Loses to Chestnut Hill, Bryn Mawr • Many fields included in Feb. Library accessions • Special feature: Hands • R. Usher in officer traininghttps://digitalcommons.ursinus.edu/weekly/1402/thumbnail.jp

Numerical simulations with a first order BSSN formulation of Einstein's field equations

We present a new fully first order strongly hyperbolic representation of the BSSN formulation of Einstein's equations with optional constraint damping terms. We describe the characteristic fields of the system, discuss its hyperbolicity properties, and present two numerical implementations and simulations: one using finite differences, adaptive mesh refinement and in particular binary black holes, and another one using the discontinuous Galerkin method in spherical symmetry. The results of this paper constitute a first step in an effort to combine the robustness of BSSN evolutions with very high accuracy numerical techniques, such as spectral collocation multi-domain or discontinuous Galerkin methods.Comment: To appear in Physical Review

On the psychological origins of tool use

The ubiquity of tool use in human life has generated multiple lines of scientific and philosophical investigation to understand the development and expression of humans' engagement with tools and its relation to other dimensions of human experience. However, existing literature on tool use faces several epistemological challenges in which the same set of questions generate many different answers. At least four critical questions can be identified, which are intimately intertwined-(1) What constitutes tool use? (2) What psychological processes underlie tool use in humans and nonhuman animals? (3) Which of these psychological processes are exclusive to tool use? (4) Which psychological processes involved in tool use are exclusive to Homo sapiens? To help advance a multidisciplinary scientific understanding of tool use, six author groups representing different academic disciplines (e.g., anthropology, psychology, neuroscience) and different theoretical perspectives respond to each of these questions, and then point to the direction of future work on tool use. We find that while there are marked differences among the responses of the respective author groups to each question, there is a surprising degree of agreement about many essential concepts and questions. We believe that this interdisciplinary and intertheoretical discussion will foster a more comprehensive understanding of tool use than any one of these perspectives (or any one of these author groups) would (or could) on their own