1,356,757 research outputs found
Pomp(a)elo y los Pomp(a)elonenses (76 a.C.-212 d.C.)
No full textEn este Trabajo de Fin de Grado se estudia y analiza el proceso de integración de Pomp(a)elo y de su comunidad (pomp(a)elonenses) en el mundo romano. Para ello, se han utilizado diferentes fuentes y métodos para conseguir un trabajo lo más preciso y completo posible, abarcando desde la fundación de la ciudad, en la década de los años 70 del siglo I a. C. hasta la plena integración de los pomp(a)elonenses a principios del siglo III a. C
Pomp(a)elo y los Pomp(a)elonenses (76 a.C.-212 d.C.)
No full textEn este Trabajo de Fin de Grado se estudia y analiza el proceso de integración de Pomp(a)elo y de su comunidad (pomp(a)elonenses) en el mundo romano. Para ello, se han utilizado diferentes fuentes y métodos para conseguir un trabajo lo más preciso y completo posible, abarcando desde la fundación de la ciudad, en la década de los años 70 del siglo I a. C. hasta la plena integración de los pomp(a)elonenses a principios del siglo III a. C
Tax Exempt Property and the Cities: Striking a Balance
No full textAll states grant a property tax exemption to certain non-profit organizations. Tax-exempt property further erodes many cities’ tax bases. Connecticut has recently adopted legislation in an attempt to solve this problem. This legislation, proposed by Professor Richard D. Pomp, provides municipalities with state subsidies for property taxes lost due to tax-exempt hospitals and colleges.
This article is the reprinted testimony of Professor Pomp before the Connecticut State Finance Committee. Professor Pomp outlines the proliferation of tax-exempt property in Connecticut, which contributes to forgone revenue for major cities. Tax-exempt property not only results in diminished tax revenue, but also imposes additional costs on cities. Professor Pomp further explains that tax-exempt organizations provide no greater net economic impact than businesses that pay the property tax. Professor Pomp analyzes three relevant questions that must be asked when considering alternatives to the current system. He concludes by proposing seven alternative options: (1) municipal permission before any taxable property can be purchased by a tax-exempt organization, (2) phase in the exemption whenever taxable property is bought by a tax-exempt organization, (3) phase out the exemption after a certain period, (4) limit the number of acres qualifying for the exemption, (5) set a dollar limit on the amount of property that can be exempt, (6) impose a user charge, or (7) state payments to jurisdictions containing tax-exempt property in excess of the state average
Rick Kay: And Now for the Rest of the Story
No full textIn this essay, Professor Pomp reflects on Richard Kay’s influence on UConn, the legal world, and on Pomp’s life.
Professor Kay was a key player in Dean Blumberg’s plan to elevate UConn to national prominence. And Pomp, after spending one day with Kay while visiting UConn for the first time, was eager to join the team.
Professor Kay was an early pioneer of the approach to constitutional interpretation known as “originalism.” Though an unpopular view in the early days of Kay’s writings, his perspective was later vindicated: originalism has since burst into the mainstream.
Pomp describes Kay’s scholarship as straight-forward and unpretentious. He lived his core beliefs with consistency; he quit teaching constitutional law when it had been emptied of content, eroded by a flood of balancing tests. He was also known by many as the funniest person on the faculty. For Pomp, Kay’s office served as a source of laughter and good feelings.
Pomp and Kay collaborated on numerous, high-profile projects. Together they motivated the creation of New York’s independent tax court. And in response to the effect of tax-exempt property on Hartford’s tax base, they drafted proposals resulting in landmark legislation that required the State to pay municipalities for taxes lost due to exempt colleges and hospitals. Also, they worked to convince the State legislature, on behalf of retailers, that gift cards should not expire.
Despite entering retirement, Kay has continued with his scholarship. Pomp suspects that Kay, a lifelong intellectual, will never fully retire from academic work
Rick Kay: And Now for the Rest of the Story
No full textIn this essay, Professor Pomp reflects on Richard Kay’s influence on UConn, the legal world, and on Pomp’s life.
Professor Kay was a key player in Dean Blumberg’s plan to elevate UConn to national prominence. And Pomp, after spending one day with Kay while visiting UConn for the first time, was eager to join the team.
Professor Kay was an early pioneer of the approach to constitutional interpretation known as “originalism.” Though an unpopular view in the early days of Kay’s writings, his perspective was later vindicated: originalism has since burst into the mainstream.
Pomp describes Kay’s scholarship as straight-forward and unpretentious. He lived his core beliefs with consistency; he quit teaching constitutional law when it had been emptied of content, eroded by a flood of balancing tests. He was also known by many as the funniest person on the faculty. For Pomp, Kay’s office served as a source of laughter and good feelings.
Pomp and Kay collaborated on numerous, high-profile projects. Together they motivated the creation of New York’s independent tax court. And in response to the effect of tax-exempt property on Hartford’s tax base, they drafted proposals resulting in landmark legislation that required the State to pay municipalities for taxes lost due to exempt colleges and hospitals. Also, they worked to convince the State legislature, on behalf of retailers, that gift cards should not expire.
Despite entering retirement, Kay has continued with his scholarship. Pomp suspects that Kay, a lifelong intellectual, will never fully retire from academic work
Home and the Range: Spencer’s Mountain as Revisionist Family Melodrama
No full textJoseph Pomp offers an analysis of Spencer’s Mountain, a film Daves’ adapted from the novel by Earl Hamner Jr. He observes that Daves’ lack of recognition by auteur theorists was that he often delved into melodramatic themes in his Westerns, themes out of favour with those who preferred the course masculinity of a John Ford or a Raoul Walsh, and who associated the melodrama with a female audience. Pomp suggests that Spencer’s Mountain provides a key window into Daves’ views on American family values, education, and class, arguing that Daves deconstructed melodrama’s ‘classic realist’ paradigm by considering a nascent feminist agenda that undermines the patriarchal underpinnings of the source novel. This, argues Pomp, creates an unusual mix – rendering Spencer’s Mountain different from most other Westerns of the period but also different from most melodramas. Ultimately, Pomp argues, Spencer’s Mountain suggests that fierce, heroic individualism has no place in Daves’ cinematic universe.</p
Statistical Inference for Partially Observed Markov Processes via the R Package pomp
No full textPartially observed Markov process (POMP) models, also known as hidden Markov models or state space models, are ubiquitous tools for time series analysis. The R package pomp provides a very flexible framework for Monte Carlo statistical investigations using nonlinear, non-Gaussian POMP models. A range of modern statistical methods for POMP models have been implemented in this framework including sequential Monte Carlo, iterated filtering, particle Markov chain Monte Carlo, approximate Bayesian computation, maximum synthetic likelihood estimation, nonlinear forecasting, and trajectory matching. In this paper, we demonstrate the application of these methodologies using some simple toy problems. We also illustrate the specification of more complex POMP models, using a nonlinear epidemiological model with a discrete population, seasonality, and extra-demographic stochasticity. We discuss the specification of user-defined models and the development of additional methods within the programming environment provided by pomp
Did South Dakota Make a Strategic Error in Drafting Its Wayfair Statute?
No full textIn this article, Professor Pomp questions whether South Dakota made a strategic error in drafting its Wayfair statute.
South Dakota, in preparation for its attack on Quill, passed S. 106. The law allows South Dakota to collect its sales tax from certain remote sellers. Pomp notes that Bellas Hess and Quill, in contrast, involved the collection of use taxes.
To aid in his analysis, Pomp considers a hypothetical case: a couple from South Dakota travels to New York City and purchases art from a gallery. The gallery packs and ships the art back to South Dakota. Must the gallery collect the South Dakota sales tax on this transaction?
To answer this question, Pomp reflects on two U.S. Supreme Court cases, Dilworth and General Trading, both decided in 1944 by Justice Frankfurter. In Dilworth, Arkansas tried to impose its sales tax on Tennessee corporations which sold machinery and mill supplies. The corporations were not qualified to do business in Arkansas and lacked sales offices, branch plant, and any place of business in Arkansas. Traveling salesmen, residents of Tennessee, provided orders to offices in Memphis via mail or telephone. Title to the goods passed upon delivery to the carrier in Memphis. The Court held that the sale took place in Tennessee, thus Arkansas could not impose its sales tax on the transaction.
Returning to the hypothetical, Pomp observes that the gallery would argue that, just like the businesses in Dilworth, it is not qualified to do business in South Dakota and has no sales office, branch plant, or any other place of business there. Lacking traveling salesmen, the gallery does not even solicit business in South Dakota. And title passes to the art in New York. Pomp argues that, under Dilworth, it does not seem that a remote vendor like the gallery is making a sale in South Dakota.
Whereas Dilworth involved the imposition of Arkansas\u27s sales tax, General Trading involved the collection of Iowa’s use tax. The facts of General Trading were nearly identical to those in Dilworth, yet Frankfurter upheld the state’s capacity under the constitution to have out-of-state vendors collect its use tax. Frankfurter distinguished General Trading in Dilworth, arguing that while the use of the Arkansas sales tax exceeded the constitutional limitations on state power, the similar application of a use tax would not.
General Trading gave market states a strategy for avoiding the constitutional difficulties of making a remote vendor collect sales tax: states should instead require the collection of their use tax. Pomp questions South Dakota’s decision to invite challenges regarding whether or not a taxable sale has occurred. General Trading provides a safer alternative: draft the statute, like those involved in Bellas Hess and Quill, around the collection of a use tax
Did South Dakota Make a Strategic Error in Drafting Its Wayfair Statute?
No full textIn this article, Professor Pomp questions whether South Dakota made a strategic error in drafting its Wayfair statute.
South Dakota, in preparation for its attack on Quill, passed S. 106. The law allows South Dakota to collect its sales tax from certain remote sellers. Pomp notes that Bellas Hess and Quill, in contrast, involved the collection of use taxes.
To aid in his analysis, Pomp considers a hypothetical case: a couple from South Dakota travels to New York City and purchases art from a gallery. The gallery packs and ships the art back to South Dakota. Must the gallery collect the South Dakota sales tax on this transaction?
To answer this question, Pomp reflects on two U.S. Supreme Court cases, Dilworth and General Trading, both decided in 1944 by Justice Frankfurter. In Dilworth, Arkansas tried to impose its sales tax on Tennessee corporations which sold machinery and mill supplies. The corporations were not qualified to do business in Arkansas and lacked sales offices, branch plant, and any place of business in Arkansas. Traveling salesmen, residents of Tennessee, provided orders to offices in Memphis via mail or telephone. Title to the goods passed upon delivery to the carrier in Memphis. The Court held that the sale took place in Tennessee, thus Arkansas could not impose its sales tax on the transaction.
Returning to the hypothetical, Pomp observes that the gallery would argue that, just like the businesses in Dilworth, it is not qualified to do business in South Dakota and has no sales office, branch plant, or any other place of business there. Lacking traveling salesmen, the gallery does not even solicit business in South Dakota. And title passes to the art in New York. Pomp argues that, under Dilworth, it does not seem that a remote vendor like the gallery is making a sale in South Dakota.
Whereas Dilworth involved the imposition of Arkansas\u27s sales tax, General Trading involved the collection of Iowa’s use tax. The facts of General Trading were nearly identical to those in Dilworth, yet Frankfurter upheld the state’s capacity under the constitution to have out-of-state vendors collect its use tax. Frankfurter distinguished General Trading in Dilworth, arguing that while the use of the Arkansas sales tax exceeded the constitutional limitations on state power, the similar application of a use tax would not.
General Trading gave market states a strategy for avoiding the constitutional difficulties of making a remote vendor collect sales tax: states should instead require the collection of their use tax. Pomp questions South Dakota’s decision to invite challenges regarding whether or not a taxable sale has occurred. General Trading provides a safer alternative: draft the statute, like those involved in Bellas Hess and Quill, around the collection of a use tax
From 30,000 Feet Into the Weeds
No full textIn this article, Professor Pomp makes various predictions regarding the future of the tax law.
Artificial intelligence will continue to change the legal landscape. The IRS uses AI to predict the likelihood of nonpayment, abusive tax returns, underreporting, and nonfiling. It also uses AI to mine social media accounts for evidence of theft and tax fraud. AI also allows firms to analyze large data sets and predict how courts will resolve legal issues in tax cases.
Pomp predicts litigation surrounding the use of market-based sourcing arising from ambiguous terms like “benefit,” “delivery,” and “use.” He also expects litigation resulting from the intersection of market-based sourcing and single-sales-factor apportionment.
Pomp hopes that “but for” reasoning, urged by states hoping for beneficial apportionment outcomes, will be rejected. These states argue that “but for” the final step in a complicated multistate transaction—the payment by a customer—there would be no income to apportion. But this perspective ignores all of the “but for” causes that were necessary for that sale to occur.
The European Union and the OECD will further recognize what the American states have known for decades: formulary apportionment is superior to arm’s-length accounting.
Pomp also expects that more taxpayers will enter into joint ventures with American Indian Tribes to exploit the case law on tribal sovereignty and immunities
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