Digital Commons Network^™

Back To The 1930s? The Shaky Case For Exempting Dividends, Reuven S. Avi-Yonah

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This article is based in part on the author’s U.S. Branch Report for Subject I of the 2003 Annual Congress of the International Fiscal Association, to be held next year in Sydney, Australia (forthcoming in Cahiers de droit fiscal international, 2003). He would like to thank Emil Sunley for his helpful comments on that earlier version, and Steve Bank, Michael Barr, David Bradford, Michael Graetz, and David Hasen for comments on this version. Special thanks are due to Yoram Keinan for his meticulous work on the EU regimes (see Appendix). All errors are the author’s. In this report, Prof. Avi-Yonah …

Integrating Visualization Into The Modeling Of Business Simulations, Victor Perotti, Tom F. Pray

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This article demonstrates the advantages of using visualization as part of the modeling process. Several examples are given to show how visualization can help developers to more completely understand the range of behaviors for their algorithms. Specifically, the Cobb Douglas function and Gold Pray demand system are examined using a tool that combines mathematical modeling with visualization capabilities.

'A Time To Build' - William W. Cook And His Architects: Edward York And Philip Sawyer, Margaret A. Leary

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The following narrative outlines the role of donor William W. cook and the architects who built the Law Quadrangle 70 years ago. The report is excerpted and adapted from 94 Law Library Journal 395-425 (2002-26). The author is director of the University of Michigan Law School's Law Library.

Incorporation Of Polarization Into The Dirsig Synthetic Image Generation Model, Jason P. Meyers, John R. Schott, Scott D. Brown

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The Digital Imaging and Remote Sensing Synthetic Image Generation (DIRSIG) model uses a quantitative first principles approach to generate synthetic hyperspectral imagery. This paper presents the methods used to add modeling of polarization phenomenology. The radiative transfer equations were modified to use Stokes vectors for the radiance values and Mueller matrices for the energy-matter interactions. The use of Stokes vectors enables a full polarimetric characterization of the illumination and sensor reaching radiances. The bi-directional reflectance distribution function (BRDF) module was rewritten and modularized to accommodate a variety of polarized and unpolarized BRDF models. Two new BRDF models based on Torrance- …

Elastic Ladar Modeling For Synthetic Imaging Applications, Robin R. Burton, John R. Schott, Scott D. Brown

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The Digital Imaging and Remote Sensing Image Generation (DIRSIG) model is a synthetic imagery generation model developed at the Center for Imaging Science (CIS) at the Rochester Institute of Technology (RIT). It is a quantitative first principle based model that calculates the sensor reaching radiance from the visible through to the long wave infrared on a spectral basis. DIRSIG generates a very accurate representation of what a sensor would see by modeling all the processes involved in the imaging chain. Currently, DIRSIG only models passive sources such as the sun and blackbody radiation due to the temperature of an object. …

Real Estate Tax Credits And Other Financial Incentives For Investing In Historic Property In The United States, Robert Pickard, Tracy Pickerill

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This paper examines the legislative and administrative background for designating historic property for protection in the United States (US) and their rehabilitation against a whole series of financial inducements and mechanisms. The preservation of heritage buildings in the US forms an integral part of the property market. Market forces and government regulations in the form of preservation law, standards for rehabilitation and the revenue code dictate the success or failure of renovating historic buildings. At all levels of governments (federal, state and local) there has been a growing reluctance in recent years to increase regulatory burdens and fiscal constraints on …

Ireland In The Eye Of The Tiger, Eamon Maher

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Reproduced by kind permission of Reality

Anisomycin Activates Jnk And Sensitises Du 145 Prostate Carcinoma Cells To Fas Mediated Apoptosis, James Curtin, Thomas Cotter

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Treatment of the hormone refractory prostate cancer cell line DU 145 with sublethal concentrations of chemotherapeutic drugs has been reported to sensitise these cells to Fas mediated apoptosis. However, the mechanism by which this occurs has not been determined. Our group has shown that inhibition of JNK activity completely abrogates the effects of chemotherapeutic drugs. Using anisomycin, a potent JNK agonist, we have demonstrated a role for JNK in Fas mediated apoptosis in DU 145 cells. Inhibition of Caspase 8 and Caspase 9 completely inhibits this process which suggests that DU 145 cells require mitochondrial amplification of the Fas apoptotic …

Many-To-Many Invocation: A New Framework For Building Collaborative Applications In Ad Hoc Networks, Hans-Peter Bischof, Alan Kaminsky

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Many-to-Many Invocation (M2MI) is a new paradigm for building collaborative systems that run in wireless proximal ad hoc networks of fixed and mobile computing devices. M2MI is useful for building a broad range of systems, including service discovery frameworks; groupware for mobile ad hoc collaboration; systems involving networked devices (printers, cameras, sensors); and collaborative middleware systems. M2MI provides an object oriented method call abstraction based on broadcasting. An M2MI invocation means ``Every object out there that implements this interface, call this method.''. M2MI is layered on top of a new messaging protocol, the Many-to-Many Protocol (M2MP), which broadcasts messages to …

Many-To-Many Invocation: A New Object Oriented Paradigm For Ad Hoc Collaborative Systems, Alan Kaminsky, Hans-Peter Bischof

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Many-to-Many Invocation (M2MI) is a new paradigm for building collaborative systems that run in wireless proximal ad hoc networks of xed and mobile computing devices. M2MI is useful for building a broad range of systems, including multiuser applications (conversations, groupware, multiplayer games); systems involving networked devices (printers, cameras, sensors); and collaborative middleware systems. M2MI provides an object oriented method call abstraction based on broadcasting. An M2MI invocation means \Every object out there that implements this interface, call this method." An M2MI-based application is built by de ning one or more interfaces, creating objects that implement those interfaces in all the …

Ion Contribution To The Astrophysical Important 447.15, 587.56 And 667.82 Nm He I Spectral Lines Broadening, Vladimir Milosavljevic, Stevan Djenize

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Characteristics of the astrophysical important Stark broadened 447.15 nm, 587.56 nm and 667.82 nm spectral line profiles have been measured at electron densities between 0.3 10 and 8.2 10 m and electron temperatures between 8000 and 33 000 K in plasmas created in five various discharge conditions using a linear, low-pressure, pulsed arc as an optically thin plasma source operated in a helium-nitrogen-oxygen gas mixture. On the basis of the observed asymmetry of the line profiles we have obtained their ion broadening parameters ( A) caused by influence of the ion microfield on the line broadening mechanism and also …

Use Of Physics Based Models In Hyperspectral Image Exploitation, John Schott, Kyungsuk Lee, Rolando Raqueno

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This paper describes a concept for using physics based models to support exploitation of remotely sensed image spectrometer data. It then reviews several methods from the literature illustrating more specifically how physics based models have been used as part of atmospheric correction, water quality assessment and temperature measurement algorithms. Finally a new approach for using model based techniques for subpixel target detection is presented This technique builds on a previously introduced invariant method that uses physics based models to support target detection of fully resolved targets without requiring in scene training or atmospheric correction. An example using the new subpixel …

Susan Philipsz, Profile, Niamh Ann Kelly

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No abstract provided.

Never Trust A Corporation, William Wilson Bratton

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I would like to start by noting multitudinous objections to assertions made in Larry Mitchell's Corporate Irresponsibility: America's Newest Export. But I waive these points for purposes of this Symposium. I would prefer to take the occasion to celebrate the book. So I will make two points on the subject of corporate social responsibility on which the book and I stand in complete accord.

On The Choice Of Optimal Temporal Control In Renewable Resource Management, Amitrajeet A. Batabyal, Hamid Beladi

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This paper addresses the following hitherto unstudied question in renewable resource management: How should a resource manager set the temporal control optimally for renewable resources such as rangelands and fisheries that are managed with spatial and temporal controls? We use a dynamic and stochastic framework to first derive the resource manager’s long run average net cost function. We then demonstrate how the temporal control can be chosen to minimize this objective function.

Speckle Observations Of Binary Stars With The Wiyn Telescope. Iii. A Partial Survey Of A, F, And G Dwarfs, Elliott P. Horch, Sarah Robinson, Zoran Ninkov, William F. Van Altena, Reed D. Meyer, Sean E. Urban, Brian D. Mason

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Two hundred thirty nearby main-sequence stars with spectral types in the range of A to G have been observed by way of speckle interferometry using the WIYN 3.5 m telescope at Kitt Peak, Arizona. The stars had no previous mention of duplicity in the literature. Of those observed, 14 showed clear evidence of a companion, and 63 were classified as suspected nonsingle based on a power spectrum analysis. The remaining stars discussed show no evidence of duplicity to the limit of the detection system in high-quality observations.

Re-Generation, Noel Brady

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Critical analysis of Sandyford Office Park, Dublin, Ireland

A Priesthood Of The Pen, Eamon Maher

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Material reproduced by kind permission of Doctrine and Life

Evaluating The 1931 Cie Color-Matching Functions, Mark Shaw, Mark Fairchild

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The use of colorimetry within industry has grown extensively in the last few decades. Central to many of today's instruments is the CIE system, established in 1931. Many have questioned the validity of the assumptions made by Wright1 and Guild,2 some suggesting that the 1931 color-matching functions are not the best representation of the human visual system's cone responses. A computational analysis was performed using metameric data to evaluate the CIE 1931 color-matching functions as compared to with other responsivity functions. The underlying assumption was that an optimal set of responsivity functions would yield minimal color-difference error between pairs of …

Miniature Microstrip Antenna With A Partially Filled High-Permittivity Substrate, Byungje Lee, Frances J. Harackiewicz

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A new technique to reduce the overall dimension of a microstrip antenna using a partially filled high-permittivity substrate is proposed. The miniaturized microstrip antenna for a repeater system in a mobile communication cellular band (824–894 MHz) is designed with the proposed technique and manufactured with light weight and small size. Comparison between simulations, based on HP HFSS software and measurements are provided.

The Once And Future Property Tax: A Dialogue With My Younger Self, Edward A. Zelinsky

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As I look back on my youth (expansively defined as the first 40 years of my life), everywhere I went, the local real property tax was perceived as both bad and doomed. If I could speak with the brash young law student/graduate student/alderman I once was, he would undoubtedly tell me, with great confidence, that by the beginning of the next century (which then seemed very far away) the property tax would no longer play a role in the system of local public finance.

Alas, he was wrong.

This essay explains why the young man I once was, confident of …

Geospatial Data Handling For Web-Based And Mobile Applications, James Carswell

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One of the main bottlenecks for web-based GIS usability is in the transmission and handling of the vast amounts of geospatial data involved. The shear volume of raster, vector, attribute, and other data to be analysed, queried, transmitted and displayed over the WWW in real-time is prohibited by connection speeds. In this paper we introduce e-Spatial technology, a fully integrated open standard web-based solution to manage multiple spatial relationships directly in an Oracle Spatial database and to deploy in real-time spatially enabled (or standard) applications completely independent of data volume. Indeed, no application code is ever installed on the client …

All American: Innovation In American Architecture, Noel Brady

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Review of American Architecture book by Brian Carter, Annette Lecuyer

Regulation And Measurement Of Oxidative Stress In Apoptosis, James Curtin, Maryanne Donovan, Thomas Cotter

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Cells are constantly generating reactive oxygen species (ROS) during aerobic metabolism. As a consequence, each cell is equipped with an extensive antioxidant defence system to combat excessive production of ROS. Oxidative stress occurs in cells when the generation of ROS overwhelms the cell's natural antioxidant defences. There is a growing consensus that oxidative stress and the redox state of a cell plays a pivotal role in regulating apoptosis, a tightly controlled form of cell death in which a cell partakes in its own demise. More recently, a role for reactive nitrogen species (RNI) as both positive and negative regulators of …

All My Rights, Carl E. Schneider

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Diane Pretty was an Englishwoman in her early 40s who had been married nearly a quarter of a century. In November 1999, she learned she had amyotrophic lateral sclerosis-in Britain, motor neurone disease. Her condition deteriorated rapidly, and soon she was "essentially paralysed from the neck downwards." She had "virtually no decipherable speech" and was fed by a tube. She was expected to live only a few months or even weeks. AB a court later explained, however, "her intellect and capacity to make decisions are unimpaired. The final stages of the disease are exceedingly distressing and undignified. AB she is …

Who Should Watch Over Refugee Law?, James C. Hathaway

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On 13 December 2001, states committed themselves" ... to consider ways that may be required to strengthen the implementation of the 1951 Convention and/or 1967 Protocol". It is wonderful that after half a century we may finally be on the verge of taking oversight of the treaty seriously.

Government Officials As Attorneys And Clients: Why Privilege The Privileged?, Melanie B. Leslie

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No abstract provided.

The Application Of The Foreign Sovereign Immunities Act To An Action Against The French Railroad For Transporting Thousands Of Jews And Others To Their Deaths: Abrams V. Sncf, Malvina Halberstam

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No abstract provided.

For Haven's Sake: Reflections On Inversion Transactions, Reuven S. Avi-Yonah

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This article discusses “inversion” transactions, in which a publicly traded U.S. corporation becomes a subsidiary of a newly established tax haven parent corporation. In the last three years, an increasing number of these transactions have been taking place, undeterred by the shareholderlevel tax imposed by the IRS on them in 1994. The article first discusses the reasons for the increasing popularity of the transactions and the tax goals they aim at achieving (primarily avoiding subpart F and U.S. earnings stripping). The article then discusses the tax policy implications of these transactions. In the short run, the article suggests that the …

The 2001 Superoutburst Of Wz Sagittae, Joseph Patterson, Gianluca Masi, Michael Richmond, Stacey Davis, Tracy Davis, Et Al.

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We report the results of a worldwide campaign to observe WZ Sagittae during its 2001 superoutburst. After a 23-year slumber at V=15.5, the star rose within 2 days to a peak brightness of 8.2, and showed a main eruption lasting 25 days. The return to quiescence was punctuated by 12 small eruptions, of ~1 mag amplitude and 2 day recurrence time; these “echo outbursts” are of uncertain origin, but somewhat resemble the normal outbursts of dwarf novae. After 52 days, the star began a slow decline to quiescence. Periodic waves in the light curve closely followed the pattern seen in …