MCA, Inc. v. United States: Judicial Recognition of the Separate Interests Theory

For United States federal tax purposes, the classificaiton of an entity as a partnership or a corporation has significant ramifications, particularly with respect to entities in foreign countries. Classification is especially important to the owners - whether shareholders or partners - of the entity because the question of whether they are taxed on their share of the profits or only upon repartriation will often depend on how the entity, set up under foreign law, is recognized by the Internal Revenue Service (Service). While entity classification in the domestic area has always been vulnerable to challenge, foreign entities face an additional problem in view of the Service\u27s application of a rather complicated separate interests test. While in theory the classification of a foreign entity embodies the same tests as the classification of a domestic entity, recent cases and revenue rulings have created uncertainty and confusion for United States taxpayers wishing to conduct some portion of their operations abroad. In MCA, Inc. v. United States, the United States Court of Appeals for the Ninth Circuit examined this problem of classifying foreign entities for federal tax purposes

Lp-cohomology of negatively curved manifolds

We compute the $L^p$-cohomology spaces of some negatively curved manifolds. We deal with two cases: manifolds with finite volume and sufficiently pinched negative curvature, and conformally compact manifolds

Readout and Control of a Power-recycled Interferometric Gravitational-wave Antenna

Interferometric gravitational wave antennas are based on Michelson interferometers whose sensitivity to small differential length changes has been enhanced by adding multiple coupled optical resonators. The use of optical cavities is essential for reaching the required sensitivity, but sets challenges for the control system which must maintain the cavities near resonance. The goal for the strain sensitivity of the Laser Interferometer Gravitational-wave Observatory (LIGO) is 10^-21 rms, integrated over a 100 Hz bandwidth centered at 150 Hz. We present the major design features of the LIGO length and frequency sensing and control system which will hold the differential length to within 5 10^-14 m of the operating point. We also highlight the restrictions imposed by couplings of noise into the gravitational wave readout signal and the required immunity against them.Comment: Presentation at ICALEPCS 2001, San Jose, November 2001, (WECT003), 3 page

VI. Regrouping Social Identities

Peer Reviewedhttp://deepblue.lib.umich.edu/bitstream/2027.42/66578/2/10.1177_0959353599009003009.pd

A Keck/DEIMOS spectroscopic survey of faint Galactic satellites: searching for the least massive dwarf galaxies

[abridged] We present the results of a spectroscopic survey of the recently discovered faint Milky Way satellites Boo, UMaI, UMaII and Wil1. Using the DEIMOS spectrograph on Keck, we have obtained samples that contain from 15 to 85 probable members of these satellites for which we derive radial velocities precise to a few km/s down to i~21-22. About half of these stars are observed with a high enough S/N to estimate their metallicity to within \pm0.2 dex. From this dataset, we show that UMaII is the only object that does not show a clear radial velocity peak. However, the measured systemic radial velocity (v_r=115\pm5 km/s) is in good agreement with recent simulations in which this object is the progenitor of the recently discovered Orphan Stream. The three other satellites show velocity dispersions that make them highly dark-matter dominated systems. In particular the Willman 1 object is not a globular cluster given its metallicity scatter over -2.0<[Fe/H]<-1.0 and is therefore almost certainly a dwarf galaxy or dwarf galaxy remnant. We measure a radial velocity dispersion of only 4.3_{-1.3}^{+2.3} km/s around a systemic velocity of -12.3\pm2.3 km/s which implies a mass-to-light ratio of ~700 and a total mass of ~5x10^5 Msun for this satellite, making it the least massive satellite galaxy known to date. Such a low mass could mean that the 10^7 Msun limit that had until now never been crossed for Milky Way and Andromeda satellite galaxies may only be an observational limit and that fainter, less massive systems exist within the Local Group. However, more modeling and an extended search for potential extra-tidal stars are required to rule out the possibility that these systems have not been significantly heated by tidal interaction.Comment: 24 pages, 11 figures, MNRAS accepte

Leo V: A Companion of a Companion of the Milky Way Galaxy

We report the discovery of a new Milky Way dwarf spheroidal galaxy in the constellation of Leo identified in data from the Sloan Digital Sky Survey. Leo V lies at a distance of about 180 kpc, and is separated by about 3 degrees from another recent discovery, Leo IV. We present follow-up imaging from the Isaac Newton Telescope and spectroscopy from the Hectochelle fiber spectrograph at the Multiple Mirror Telescope. Leo V's heliocentric velocity is 173.4 km/s, which is offset by about 40 km/s from that of Leo IV. A simple interpretation of the kinematic data is that both objects may lie on the same stream, though the implied orbit is only modestly eccentric (e = 0.2)Comment: Submitted to ApJ (Letters

Investigation of the New Local Group Galaxy VV 124

We present the results of our stellar photometry and spectroscopy for the new Local Group galaxy VV 124 (UGC 4879) obtained with the 6-m BTA telescope. The presence of a few bright supergiants in the galaxy indicates that the current star formation process is weak. The apparent distribution of stars with different ages in VV 124 does not differ from the analogous distributions of stars in irregular galaxies, but the ratio of the numbers of young and old stars indicates that VV 124 belongs to the rare Irr/Sph type of galaxies. The old stars (red giants) form the most extended structure, a thick disk with an exponential decrease in the star number density to the edge. Definitely, the young population unresolvable in images makes a great contribution to the background emission from the central galactic regions. The presence of young stars is also confirmed by the [O III] emission line visible in the spectra that belongs to extensive diffuse galactic regions. The mean radial velocity of several components (two bright supergiants, the unresolvable stellar population, and the diffuse gas) is v_h = -70+/-15 km/s and the velocity with which VV 124 falls into the Local Group is v_LG = -12+/-15 km/s. We confirm the distance to the galaxy D = 1.1+/-0.1 Mpc and the metallicity of red giants ([Fe/H] = -1.37) found by Kopylov et al. (2008).VV 124 is located on the periphery of the Local Group approximately at the same distance from M 31 and our Galaxy and is isolated from other galaxies. The galaxy LeoA nearest to it is 0.5 Mpc away.Comment: 10 pages, 8 figures. Accepted for publication in Astronomy Letters (2010, Vol. 36, No. 5, pp. 309-318

A Wide Field Survey of Satellite Galaxies around the Spiral Galaxy M106

We present a wide field survey of satellite galaxies in M106 (NGC 4258) covering a 1.7\degr \times 2\degr field around M106 using Canada-France-Hawaii Telescope/MegaCam. We find 16 satellite galaxy candidates of M106. Eight of these galaxies are found to be dwarf galaxies that are much smaller and fainter than the remaining galaxies. Four of these galaxies are new findings. Surface brightness profiles of 15 out of 16 satellite galaxies can be represented well by an exponential disk profile with varying scale length. We derive the surface number density distribution of these satellite galaxies. The central number density profile (d $<100$ kpc) is well fitted by a power-law with a power index of $-2.1\pm0.5$, similar to the expected power index of isothermal distribution. The luminosity function of these satellites is represented well by the Schechter function with a faint end slope of $-1.19^{+0.03}_{-0.06}$. Integrated photometric properties (total luminosity, total colour, and disk scale length) and the spatial distribution of these satellite galaxies are found to be roughly similar to those of the Milky Way and M31.Comment: Accepted by MNRA