A History of Tax Regulation Prior to the Administrative Procedure Act

The relationship of the Administrative Procedure Act (APA) to tax administration has been the subject of increasing scrutiny from scholars and courts. Some of this scrutiny has critiqued the long-held view of the Department of Treasury that tax regulations issued under the general grant of authority in I.R.C. § 7805(a) are interpretative regulations within the meaning of the APA. This Article reviews the almost 150–year history of tax administration before the enactment of the APA to show the origins and basis for this long-held view. The Article also argues that the application of the general terms of the APA to tax administration must be informed by this pre–APA history of tax regulation

The effective acoustic environment of helicopter crewmen

Methods of measuring the composite acoustic environment of helicopters in order to quantify the effective acoustic environment of the crewmen and to assess the real acoustic hazards of the personnel are examined. It is indicated that the attenuation characteristics of the helmets and hearing protectors and the variables of the physiology of the human ear be accounted for in determining the effective acoustic environment of Army helicopter crewmen as well as the acoustic hazards of voice communications systems noise

Automatic signal range selector for metering devices Patent

Voltage range selection apparatus for sensing and applying voltages to electronic instruments without loading signal sourc

Wind shear modeling for aircraft hazard definition

Mathematical models of wind profiles were developed for use in fast time and manned flight simulation studies aimed at defining and eliminating these wind shear hazards. A set of wind profiles and associated wind shear characteristics for stable and neutral boundary layers, thunderstorms, and frontal winds potentially encounterable by aircraft in the terminal area are given. Engineering models of wind shear for direct hazard analysis are presented in mathematical formulae, graphs, tables, and computer lookup routines. The wind profile data utilized to establish the models are described as to location, how obtained, time of observation and number of data points up to 500 m. Recommendations, engineering interpretations and guidelines for use of the data are given and the range of applicability of the wind shear models is described

Functional implications of size reduction in molar dentition during human evolution : using 3D printed models

During hominin evolution the size of postcanine dentition has varied. While many researchers have tried to make predictions as to the functional significance of these changes, the effect of tooth size on food breakdown has not been quantified.This thesis develops a novel physical testing rig to compare the fracture performance of teeth of differing sizes on the breakdown of food replicas to examine the relationship between tooth size, food size and breakdown performance. This work presents the design protocol and sensitivity studies carried out in order to develop the methodology for subsequent investigations into dental mechanics.To examine the effect of dental reduction during human evolution on hard food breakdown stainless steel dental models of a modern Homo sapiens upper and lower dental row were isometrically scaled up. A size series of physical dental rows were attached to a universal testing machine and the efficiency of food breakdown recorded for each (force at initial fracture, energy, displacement and fragmentation), using 3D printed spherical hard brittle food replicas with diameters of 5mm, 10mm, 15mm, and 20mm.The results of this study suggest that smaller teeth of modern Homo sapiens are slightly more efficient at reducing peak forces and energy consumption of initial fracture of food objects than larger teeth. However, compared to the effect of changes in food size and the location of the bite on the tooth, performance differences between the different tooth sizes were minimal. The results suggest that individuals may be able to access different stress resistant food resources by simply changing how they position a food item, but also suggest that dental reduction during human evolution may have had a minimal impact on the ability of the individual to break hard food items of varying sizes. This study highlights the conflicting constraints placed on teeth and considers the evolutionary, developmental and mechanical mechanisms that may have resulted in the reduced molar size we see during human evolution

Taxation of Electronic Gaming

At a doctrinal level, the subject of this Article is timely. During this time of the coronavirus pandemic, casinos have been closed and large populations have been subject to stay-home orders from local and state authorities. One can reasonably expect a large increase in electronic gaming and thus an increased need for proper consideration of its taxation. This Article argues for a cash-out rule of taxation. At a deeper level, the subject of this Article is timeless. Tax law is wickedly complex for a reason. This Article explores that complexity using the example of electronic gaming. It grapples with the source of that complexity: an inherent and unresolvable tension between economic theories of income and the practical needs of administering a system of taxation to a large population in a democracy. That tension led some scholars to argue for a standards-based approach to taxation. This Article considers and rejects that argument. Legal rules are necessary to mediate between theory and practice. Hence, this Article demonstrates the continued relevance and importance of doctrinal analysis in legal scholarship

Bound by the BAP: The Stare Decisis Effects of BAP Decisions

Bankruptcy Appellate Panels (BAPs) are used as an intermediate review of bankruptcy final orders, judgments and decrees, between the district court and circuit court of appeals. The precedential value of BAP decisions, however, has long been in dispute. This article examines the history of BAPs and analyzes the doctrine of stare decisis in relation to these courts. The author argues that BAP decisions should bind both bankruptcy and district courts within a circuit. A secondary theme argues again disbanding BAPs, a proposal put forward by the National Bankruptcy Review Commission