1,724,215 research outputs found
Internal Revenue Code Section 7701(b): A More Certain Definition of Resident
No full textThe purpose of this Note is four-fold. First, it seeks to articulate the central concepts underlying taxation of nonresidents and residents. In so doing, the discussion endeavors to show the importance of section 7701(b) of the Internal Revenue Code. Second, it attempts to cancas the case law and pertinent regulations and rulings and highlight the ambiguities therein. Third, the discussion will address the essential features of section 7701(b) and illustrate Congress\u27 new approach to the problem of determining resident status for aliens. Finally, the policy implications of 7701(b) are examined and suggestions for further improvement are made
Internal Revenue Code Section 7701(b): A More Certain Definition of Resident
No full textThe purpose of this Note is four-fold. First, it seeks to articulate the central concepts underlying taxation of nonresidents and residents. In so doing, the discussion endeavors to show the importance of section 7701(b) of the Internal Revenue Code. Second, it attempts to cancas the case law and pertinent regulations and rulings and highlight the ambiguities therein. Third, the discussion will address the essential features of section 7701(b) and illustrate Congress\u27 new approach to the problem of determining resident status for aliens. Finally, the policy implications of 7701(b) are examined and suggestions for further improvement are made
Internal Revenue Code Section 7701(b): A More Certain Definition of Resident
No full textThe purpose of this Note is four-fold. First, it seeks to articulate the central concepts underlying taxation of nonresidents and residents. In so doing, the discussion endeavors to show the importance of section 7701(b) of the Internal Revenue Code. Second, it attempts to cancas the case law and pertinent regulations and rulings and highlight the ambiguities therein. Third, the discussion will address the essential features of section 7701(b) and illustrate Congress\u27 new approach to the problem of determining resident status for aliens. Finally, the policy implications of 7701(b) are examined and suggestions for further improvement are made
[The Texas & Pacific R.R., Engine Drawing Card, Sketch No. 7701]
No full textThis engine drawing card was created for Texas & Pacific Railway, Class 12-1 1/2-42 1/4 D. Section J- 12 1/4E. Sketch 7701. Copy Spec. [field left blank]
[The Texas & Pacific R.R., Engine Drawing Card, Sketch No. 7701]
No full textThis engine drawing card was created for Texas & Pacific Railway, Class 12-1 1/2-42 1/4D. Section J-12 1/4D. Sketch 7701. Copy Spec. [field left blank]
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
Estimating seasonal variations in cloud droplet number concentration over the boreal forest from satellite observations
Get PDFSeasonal variations in cloud droplet number concentration (<i>N</i><sub>CD</sub>) in low-level stratiform clouds over the boreal forest are estimated from MODIS observations of cloud optical and microphysical properties, using a sub-adiabatic cloud model to interpret vertical profiles of cloud properties. An uncertainty analysis of the cloud model is included to reveal the main sensitivities of the cloud model. We compared the seasonal cycle in <i>N</i><sub>CD</sub>, obtained using 9 yr of satellite data, to surface concentrations of potential cloud activating aerosols, measured at the SMEAR II station at Hyytiälä in Finland. The results show that <i>N</i><sub>CD</sub> and cloud condensation nuclei (CCN) concentrations have no clear correlation at seasonal time scale. The fraction of aerosols that actually activate as cloud droplet decreases sharply with increasing aerosol concentrations. Furthermore, information on the stability of the atmosphere shows that low <i>N</i><sub>CD</sub> is linked to stable atmospheric conditions. Combining these findings leads to the conclusion that cloud droplet activation for the studied clouds over the boreal forest is limited by convection. Our results suggest that it is important to take the strength of convection into account when studying the influence of aerosols from the boreal forest on cloud formation, although they do not rule out the possibility that aerosols from the boreal forest affect other types of clouds with a closer coupling to the surface
Variations on the Author
Get PDF“Variations on the Author” discusses two of Eduardo Coutinho’s recent films (Um Dia na Vida, from 2010, and Últimas Conversas, posthumously released in 2015) and their contribution to the general question of documentary authorship. The director’s filmography is characterized by a consistent yet self-effacing form of authorial self-inscription: Coutinho often features as an interviewer that rather than express opinions propels discourses; an interviewer that is good at listening. This mode of self-inscription characterizes him as an author who is not expressive but who is nonetheless markedly present on the screen. In Um Dia na Vida, however, Coutinho is completely absent form the image, while Últimas Conversas, on the contrary, includes a confessional prologue that moves the director from the margins to the center of his films. This article examines the ways in which these works stand out in the filmography of a director who offers new insights into the notion of cinematic authorship
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