Innocence in the Eyes of the Internal Revenue Service

The filing of a joint return by a married couple usually results in overall tax savings. The downside of filing jointly, however, is that the parties to the joint return are together, and individually, responsible for the accuracy of the return, for the full tax liability, and for any interest or penalty relating to the return. This so-called joint and several liability extends not only to the tax shown on the return, but also to any tax that should have been but was not reported on the return. Consequently, each spouse becomes responsible for the tax infractions of the other. Because the joint and several liability rule was found to be overly harsh, since 1971, the tax law has contained a provision under which a spouse could seek relief from liability if he or she met the definition of an innocent spouse. As it turned out, however, the requirements that had to be met in order to obtain innocent spouse relief were very stringent and failed to protect spouses, in most cases the wife or ex-wife, where fairness dictated that relief was warranted. Accordingly, in 1998, Congress significantly liberalized the rules for obtaining innocent spouse relief by enacting a new section of the Internal Revenue Code and expunging the prior provisions. This paper analyzes the new Code section and also analyzes a recent Revenue Procedure, issued in 2000, that details the requirements for obtaining innocent spouse relief under one of the provisions of the new law, namely, equitable relief

The Theme Park Throwdown: The Successes and Failures of IP-Related Attractions and Expansions in Disney Theme Parks and Strategies for the Future

The Disney brand invokes strong feelings of loyalty from supporters and dissatisfaction from its opponents, and it many facets play an important part in society (Havard et al., 2021). It is certainly true that “the Magical World of Disney remains unsurpassed in terms of brand name recognition, planning complexity, and detailed execution. It is the paradigmatic ideal of how architecture can establish a universe around its landscape” (Dalov, 2019, p.10). For nearly 70 years, the Imagineers cultivated an idea from the mind of one man into a global phenomenon of twelve theme parks and counting (Tang & Iwerks, 2019). The Disney park is a grandiose land made accessible to mere humans. One forgets about aching feet as he races from one adventure to the next. The clean, safe environment is welcoming to guests of all ages. Complete strangers are impeccably kind to one another as they wait in line making pleasant conversation. Regardless of where the park is in the world, it is meant to be an escape: “Disney is not just offering entertainment: The Company is also selling… an antidote to everyday life. What we buy [at Disney] is not just fun and souvenirs but is also a welcome civility on a human scale” (Fjellman, 2019, p. 31)

Estate Tax Aggregation Theory: IRS Continues Its Losing Ways

Sophisticated estate planning encompasses the concept of valuation discounting. Discounting can be accomplished by transferring fractional parts of a property interest, or arranging things so that only a fractional part is owned at death. A minority and/or market discount is claimed for the fractional interest. The IRS has unsuccessfully challenged fractionalization using an aggregation theory under which interests of family members in the property are combined into a majority interest, precluding a minority discount. In two 1999 Tax Court cases, the IRS also lost when it attempted to expand its aggregation theory to include stock held in a so-called QTIP trust. This paper examines these cases and also explores other estate tax issues

Riemannian Flows for Supervised and Unsupervised Geometric Image Labeling

In this thesis we focus on the image labeling problem, which is used as a subroutine in many image processing applications. Our work is based on the assignment flow which was recently introduced as a novel geometric approach to the image labeling problem. This flow evolves over time on the manifold of row-stochastic matrices, whose elements represent label assignments as assignment probabilities. The strict separation of assignment manifold and feature space enables the data to lie in any metric space, while a smoothing operation on the assignment manifold results in an unbiased and spatially regularized labeling. The first part of this work focuses on theoretical statements about the asymptotic behavior of the assignment flow. We show under weak assumptions on the parameters that the assignment flow for data in general position converges towards integral probabilities and thus ensures unique assignment decisions. Furthermore, we investigate the stability of possible limit points depending on the input data and parameters. For stable limits, we derive conditions that allow early evidence of convergence towards these limits and thus provide convergence guarantees. In the second part, we extend the assignment flow approach in order to impose global convex constraints on the labeling results based on linear filter statistics of the assignments. The corresponding filters are learned from examples using an eigendecomposition. The effectiveness of the approach is numerically demonstrated in several academic labeling scenarios. In the last part of this thesis we consider the situation in which no labels are given and therefore these prototypical elements have to be determined from the data as well. To this end we introduce an additional flow on the feature manifold, which is coupled to the assignment flow. The resulting flow adapts the prototypes in time to the assignment probabilities. The simultaneous adaptation and assignment of prototypes not only provides suitable prototypes, but also improves the resulting image segmentation, which is demonstrated by experiments. For this approach it is assumed that the data lie on a Riemannian manifold. We elaborate the approach for a range of manifolds that occur in applications and evaluate the resulting approaches in numerical experiments

Tax Court Reverses Course on Deductions for MBA Costs

Obtaining an MBA degree is an expensive and time-consuming process. The cost is ameliorated, however, if a tax deduction can be taken. Although many in the business community believe they are entitled to deduct the costs of obtaining an MBA, the fact of the matter is that a deduction is not a certainty. There have been numerous litigated cases concerning whether a deduction for the cost of an MBA should be allowed. The cases reveal, however, that it all depends on the particular facts and circumstances. This paper reviews the case law concerning the deductibility of the costs of obtaining an MBA: first some older cases, then some more recent cases, and finally the most recent case decided in 2005. Based upon two cases decided by the Tax Court in 2002 and 2004, in which the taxpayers lost, tax practitioners were concerned that a tax deduction for the cost of an MBA was virtually foreclosed for everyone. But in the case decided in 2005, it appears that the Tax Court softened its position. Accordingly, it seems that there is still the possibility of deducting the cost of an MBA. But again, it’s not automatic and will depend on the facts

A biocompatible, heparin-binding polycation for the controlled delivery of growth factors

The delivery of growth factors has been attempted for a number of different therapies. The approach of delivering therapeutic growth factors in a safe and efficient manner is difficult and certain criteria should be met. These criteria include: binding the appropriate growth factors, maintaining their bioactivity, and delivering these proteins with controllable release kinetics for an extended period of time. These criteria encompass a set of guidelines that hope to mimic in vivo biological events such as neovascularization. The central goal of this thesis is to meet these criteria by introducing a novel delivery strategy for growth factors using a biocompatible polycation and heparin. It was hypothesized that a polycation could interact with heparin to form a complex with the potential to deliver bioactive growth factors with an adaptable release. This hypothesis was tested by examining the release kinetics of bFGF from the complex and investigating whether the released bFGF maintained its bioactivity. The [polycation:heparin:bFGF] complex was formed by mixing the components in water, resulting in a precipitate. This precipitate was able to deliver bFGF with controllable release kinetics and the bioactivity of the released bFGF was higher than bolus bFGF and comparable to heparin stabilized bFGF. This system is expected to have the ability to bind and deliver numerous heparin-binding growth factors. In conclusion, the delivery system developed in this research provides a novel mechanism for controlled release of growth factors. This delivery strategy has met the criteria listed earlier and this research has laid the foundation for a successful delivery vehicle. Further, a biocompatible polycation was synthesized, which is a critical component of the delivery system. This polycation exhibited in vitro and in vivo biocompatibility that was orders of magnitude higher than existing polycations and has the potential to be very useful in a variety of biomedical applications. This design principle is also expected to serve as a platform for the synthesis of other biocompatible polycations.Ph.D.Committee Chair: Wang, Yadong; Committee Member: Barker, Thomas; Committee Member: Boyan, Barbara; Committee Member: Chaikof, Elliot; Committee Member: Meredith, J. Carson; Committee Member: Prausnitz, Mar