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High temperature deformation in 2036 Al and 0.2 wt % Zr-2036 A1
Get PDFThe microstructure and high-temperature deformation of 2036 Al and a 0.2 wt % Zr modified 2036 Al were characterized. A particle-simulated- nucleation process was applied to refine grain structure in both alloys. Thermomechanically processed materials were tested from 450 to 500 C and strain rates from 2{times}10{sup {minus}1} to 2{times}10{sup {minus}4}s{sup {minus}1}. Strain rate sensitivity exponent, activation energy, and total elongation were measured, and the deformation mechanism was proposed. Effect of Zr on microstructure and deformation of 2036 Al at elevated temperatures was discussed
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Loopholes and Ambiguities of Section 2036
No full textThe possibility of divergent tax treatment of economically similar situations has made section 2036 of the Internal Revenue Code\u27 one of the most abused of the federal estate tax provisions. Originally enacted to ensure inclusion within the gross estate of the value of all property ostensibly transferred by the decedent prior to his death and yet beneficially enjoyed by him during his lifetime, the section is being circumvented by an increasing number of tax avoidance patterns. Although some of the confusion can be traced to the erratic approach of the courts to cases involving section 2036, the primary interpretive difficulty stems from Congress\u27 failure to define precisely what it hoped to accomplish by the enactment of that section. Under section 2036, the inter vivos gift of property in which the lifetime income is reserved for the transferor is clearly includible in the gross estate of the decedent-transferor. On the other hand, it is equally clear that the transferor may accomplish the same economic result, without subjecting the property to inclusion within his taxable estate by virtue of section 2036, simply by dividing his property and giving away an amount equal to the actuarial value of the remainder interest while retaining an amount equal to the actuarial value of the lifetime income. Taxation under section 2036 thus seems to turn on the form utilized by the decedent in dividing and transferring his property, rather than on the economic result. Unfortunately, most of the tax avoidance patterns fall within the gray area between the two forms of transfers mentioned above. A discussion of some of these patterns may serve to focus attention on the need for a review of the congressional purpose underlying section 2036 and for a possible statutory recasting of that section
Loopholes and Ambiguities of Section 2036
Get PDFThe possibility of divergent tax treatment of economically similar situations has made section 2036 of the Internal Revenue Code\u27 one of the most abused of the federal estate tax provisions. Originally enacted to ensure inclusion within the gross estate of the value of all property ostensibly transferred by the decedent prior to his death and yet beneficially enjoyed by him during his lifetime, the section is being circumvented by an increasing number of tax avoidance patterns. Although some of the confusion can be traced to the erratic approach of the courts to cases involving section 2036, the primary interpretive difficulty stems from Congress\u27 failure to define precisely what it hoped to accomplish by the enactment of that section. Under section 2036, the inter vivos gift of property in which the lifetime income is reserved for the transferor is clearly includible in the gross estate of the decedent-transferor. On the other hand, it is equally clear that the transferor may accomplish the same economic result, without subjecting the property to inclusion within his taxable estate by virtue of section 2036, simply by dividing his property and giving away an amount equal to the actuarial value of the remainder interest while retaining an amount equal to the actuarial value of the lifetime income. Taxation under section 2036 thus seems to turn on the form utilized by the decedent in dividing and transferring his property, rather than on the economic result. Unfortunately, most of the tax avoidance patterns fall within the gray area between the two forms of transfers mentioned above. A discussion of some of these patterns may serve to focus attention on the need for a review of the congressional purpose underlying section 2036 and for a possible statutory recasting of that section
Section 2036 Proves Potent IRS Weapon Against Family Limited Partnerships
Get PDFTaxpayers’ successful uses of Family Limited Partnerships (FLPs) to shield wealth from estate taxes and gift taxes are being challenged by the IRS with Code Section 2036. Sec. 2036 “pulls back” into the taxable estate all assets over which the taxpayer retains direct or indirect control, subjecting them to transfer taxes. These assets can include those transferred to FLPs where taxpayers act carelessly in conducting relationships with the entity. The IRS’ use of Code Section 2036 has recently resulted in taxpayer losses in court and now represents the major challenge to a FLP’s viability. To assist accountants and their clients engaged in FLPs, this article analyzes Sec. 2036 and details current tax developments, particularly the June 2003 decision in the remanded case of Strangi. The article also provides specific tax planning procedures for accountants to undertake when advising clients engaged in FLPs, so as to safeguard taxpayers’ assets against Sec. 2036 attack
Going Beyond Counting First Authors in Author Co-citation Analysis
Get PDFThe present study examines one of the fundamental aspects of author co-citation analysis (ACA) - the way co-citation
counts are defined. Co-citation counting provides the data on which all subsequent statistical analyses and mappings
are based, and we compare ACA results based on two different types of co-citation counting - the traditional type that
only counts the first one among a cited work's authors on the one hand and a non-traditional type that takes into
account the first 5 authors of a cited work on the other hand. Results indicate that the picture produced through this non-traditional author co-citation counting contains more coherent author groups and is therefore considerably clearer. However, this picture represents fewer specialties in the research field being studied than that produced through the traditional first-author co-citation counting when the same number of top-ranked authors is selected and analyzed. Reasons for these effects are discussed
Dermatology Workforce Projections in the United States, 2021 to 2036
No full textBACKGROUND: There has been a growing imbalance between supply of dermatologists and demand for dermatologic care. To best address physician shortages, it is important to delineate supply and demand patterns in the dermatologic workforce. The goal of this study was to explore dermatology supply and demand over time.
METHODS: We conducted a cross-sectional analysis of workforce supply and demand projections for dermatologists from 2021 to 2036 using data from the Health Workforce Simulation Model from the National Center for Health Workforce Analysis. Estimates for total workforce supply and demand were summarized in aggregate and stratified by rurality. Scenarios with status quo demand and improved access were considered.
RESULTS: Projected total supply showed a 12.45% increase by 2036. Total demand increased 12.70% by 2036 in the status quo scenario. In the improved access scenario, total supply was inadequate for total demand in any year, lagging by 28% in 2036. Metropolitan areas demonstrated a relative supply surplus up to 2036; nonmetropolitan areas had at least a 157% excess in demand throughout the study period. In 2021 adequacy was 108% and 39% adequacy for metropolitan and nonmetropolitan areas, respectively; these differences were projected to continue through 2036.
CONCLUSIONS: The findings suggest that the dermatology physician workforce is inadequate to meet the demand for dermatologic services in nonmetropolitan areas. Furthermore, improved access to dermatologic care would bolster demand and especially exacerbate workforce inadequacy in nonmetropolitan areas. Continued efforts are needed to address health inequities and ensure access to quality dermatologic care for all
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