101,923 research outputs found

    Strangi: A Critical Analysis And Planning Suggestions

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    In Strangi, the Tax Court eliminated all estate tax discounts for a family partnership. It held, as it had in several prior cases, that section 2036(a)(1) required this result. The court then went on to reach the alternative holding that section 2036(a)(2) likewise precluded the estate from claiming a discount. While many have taken steps to address the threat that section 2036(a)(1) poses to these partnerships, few, if any, anticipated the court\u27s alternative holding and the potentially critical threat it poses if sustained. The authors argue that the alternative holding is based on a misreading of the Supreme Court\u27s decision in Byrum and is inconsistent with the Service\u27s own published guidance. They go on to suggest various planning strategies for existing and new partnerships that will neutralize this new threat, concluding that Strangi\u27s alternative holding is not only an imperfect solution for abusive partnership discounts but also nothing more than a trap for the unwary

    Strangi: A Critical Analysis And Planning Suggestions

    No full text
    In Strangi, the Tax Court eliminated all estate tax discounts for a family partnership. It held, as it had in several prior cases, that section 2036(a)(1) required this result. The court then went on to reach the alternative holding that section 2036(a)(2) likewise precluded the estate from claiming a discount. While many have taken steps to address the threat that section 2036(a)(1) poses to these partnerships, few, if any, anticipated the court\u27s alternative holding and the potentially critical threat it poses if sustained. The authors argue that the alternative holding is based on a misreading of the Supreme Court\u27s decision in Byrum and is inconsistent with the Service\u27s own published guidance. They go on to suggest various planning strategies for existing and new partnerships that will neutralize this new threat, concluding that Strangi\u27s alternative holding is not only an imperfect solution for abusive partnership discounts but also nothing more than a trap for the unwary

    Light controlled bending of a holographic transmission phase grating

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    We recorded a permanent phase transmission grating on a thin film made by using a recently developed holographic photomobile mixture. The recorded grating pitch falls in the visible range and can be optically manipulated by using an external coherent or incoherent low power light source. When the external light source illuminates the grating the entire structure bends and, as a consequence, the optical properties of the grating change. This peculiarity makes it possible to use the recorded periodic structure as an all-optically controlled free standing thin colour selector or light switch depending on the source used to illuminate the grating itself. Additionally, it could open up new possibilities for stretchable and reconfigurable holograms controlled by light as well as thin devices for optically reconfigurable dynamic communications and displays

    Soliton-assisted random lasing in liquid crystals

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    We demonstrate random lasing control exploiting optical gain and light self-localization in a reorientational medium. A spatial soliton in dye-doped nematic liquid crystals modulates stimulated emission of visible light, yielding random lasing with enhanced features

    Introduction into Italy of Gryon pennsylvanicum (Ashmead), an egg parasitoid of the alien invasive bug Leptoglossus occidentalis Heidemann

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    Leptoglossus occidentalis (Heteroptera, Coreidae), a Nearctic species, was accidentally introduced into Northern Italy in the late 1990s, from where it has spread throughout Europe. The bug causes abortion of immature cones of Pinus pinea L., with economic impact on the pine-nut industry. As part of a pest control research program, the egg parasitoid Gryon pennsylvanicum Ashmead (Hymenoptera, Platygastridae) was collected from British Columbia, Canada, and legally introduced to a quarantine climatic chamber in Florence, Italy. The egg parasitoid will be tested against native non target heteropterans, an environmental impact assessment will be conducted, and a mass rearing method will be developed if appropriate. The ultimate goal is to release G. pennsylvanicum into Italian P. pinea forests for classical biological control of L. occidentalis

    Bibliographie Hilarion G. Petzold 1958 – 2009 mit Anhang als Einführung

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    Dieses Archiv enthält die Gesamtbibliographie der Werke des Autors nebst einiger Texte „Über H. G. Petzold“ im Schlussteil der Bibliographie sowie einen Anhang mit einer Einführung in die Architektur des Werkes in seinem wissenslogischen Aufbau als Ausarbeitung seines „Tree of Science Modells“ (2007).This archive contains the complete bibliography of the author and some texts about H. G. Petzold, moreover an epilogue with an introduction to the architecture of the works in its epistemological structure and composition and as an elaborations of Petzold’s „Tree of Science Modell (2007).https://www.fpi-publikation.de/polyloge/01-2009-petzold-h-g-gesamtbibliographie-h-g-petzold-1958-2009-updating-november2009/peerReviewedpublishedVersio

    Dispelling the Myths Behind First-author Citation Counts

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    We conducted a full-scale evaluative citation analysis study of scholars in the XML research field to explore just how different from each other author rankings resulting from different citation counting methods actually are, and to demonstrate the capability of emerging data and tools on the Web in supporting more realistic citation counting methods. Our results contest some common arguments for the continued use of first-author citation counts in the evaluation of scholars, such as high correlations between author rankings by first-author citation counts and other citation counting methods, and high costs of using more realistic citation counting methods that are not well-supported by the ISI databases. It is argued that increasingly available digital full text research papers make it possible for citation analysis studies to go beyond what the ISI databases have directly supported and to employ more sophisticated methods
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