The taxpayer filed a suit in the us district court world for the district of Minnesota. Under the sham transaction doctrine, a transaction is a sham, and is disregarded, if: It is not motivated by any economic purpose outside of tax considerations (the business purpose test). It is without economic substance because no real potential for profit exists (the economic substance test). The us district court held that the Bx payment was pre-tax revenue that should be regarded as an item of income in applying the economic substance test. The us district court explained that, although the Bx payment was clearly derived by reference to the uk tax benefits to the uk corporation, that reference does not convert the private payment into some kind of government disbursement or refund, which would be excluded from. The us district court then denied the taxpayer's motion for partial summary judgment that the stars transaction satisfied the business purpose test. The us district court explained that the us tax benefits at issue derived from the taxpayer's willingness voluntarily to subject income produced by us assets to a uk income tax, but that no authority was citied or found for the proposition that voluntarily submitting.
Observing Mode : giraffe/ifu, hr12, L5 Exposure time : 18000s (9000s per setup) S/N to be Achieved : Conditions : dark time, seeing irrelevant coordinator :. The us district court for the district of Minnesota has partly granted and partly denied motions for summary judgment to a taxpayer with regard to a structured transaction that generated foreign tax credits (FTCs) (Wells Fargo companies,. United States of America, civil. The case involved a us taxpayer who entered into a highly structured series of transactions, referred to as the "stars transaction.". In the stars transaction, the taxpayer effectively transferred existing income-producing assets to a uk trust, with the result that the income realized by the uk trust from the contributed assets was subject to a uk income tax. Under us law, the uk trust was treated as part of the taxpayer, and therefore the uk income taxes paid by the uk trust were treated as paid by the taxpayer for purposes of its consolidated us income tax return. The stars transaction also created uk tax credits and uk deductions for a uk financial services corporation, which in return paid the taxpayer a percentage of the uk tax credits (Bx payments). When the taxpayer filed its us income tax return, the taxpayer claimed a number of us tax benefits from the transaction, including ftcs attributable to the uk taxes and expenses attributable to the transaction. The us internal revenue service (IRS) took the position that the stars transaction was a sham transaction and should therefore be disregarded.
Book summary - cliffsNotes
Piotto ngc 2243 - ra06:29:48.0 dec-31:17:00 Elemental Abundance in ngc 2243 summary objective: to derive fe and other elemental abundances for subgiant stars and membership information for turnoff stars (this cluster has the same metallicity of 47 Tuc, but formed 10-12 Gyr later) Observing Mode. Pasquini ms ra10:57:00.2 dec-03:37:27 Kinematics of Distant Galaxies from flames-giraffe ifu mode summary objective: to derive, from spatially resolved-spectroscopy and hst images, velocity fields and rotation curves for galaxies with emission lines between redshift.4 and.9; to kinematically map merging systems in order. Cayatte ngc 1310 (eso 357-G19) - ra03:21:03.5 dec-37:06:07 Dark and Stellar Mass in Late-type Dwarfs summary objective : to make a direct measure of the product between the stellar mass-to-light ratio and of the thickness of the disk from the stellar vertical velocity dispersion (i.e. The line-of-sight dispersion of a face-on late-type dwarf). 5 ifus to be allocated at a radius of 1 scale length and 10 at a radius of 2 scale lengths. Selection of target is based on: late type, close to face-on, and not barred. It is less massive than the milky way, so a velocity resolution of the order thesis of 10-20 km/s is needed.
Observing Mode: giraffe/ifu (0.52 microlens lr4 Exposure time: 5h total S/N to be Achieved: 10 - 20 Conditions: seeing irrelevant, clear, dark coordinator :. Cretton Orion - ra05:35:17.0 dec-05:23:28 Probing Activity and Angular Momentum evolution of low-mass members of Orion Nebular Cluster summary objective: to determine the Vsini distribution for a large number (120) of low-mass stars in the onc in order to properly study the early angular momentum. The Vsini, combined with already available rotational periods, will also yield the minimum radius and possibly the radii distribution, hence an independent measure of this population age. Observing Mode: giraffe/Medusa, hr14, hr15 Exposure time: 10h total S/N to be Achieved: 15-40 (HR14) and 20-60 (HR15) depending on magnitude of target Conditions: seeing.2 airmass.4 coordinator:. Melo ngc 3585 - ra11:13:17.0 dec-26:45:20 Dynamical Study of Elliptical Galaxies Objective : to accurately determine the velocity dispersion and infer some constraint on the Ellipsoid of velocity dispersions in the central part of the galaxy. The set of high resolution ifuobservations will also permit to evaluate the accuracy of low S/N observations (single spectrum) compared to che co-added spectra results.
Cioni centaurus a (ngc 5128) - ra13:25:28 dec-43:01:06 Massive kinematic Study of ngc 5128 using its planetary nebulae and globular clusters as test probes summar y objective: to obtain the velocity of all catalogued pne (785, cf hui. 1993 at a wavelength accuracy 10km/s using the brightest line, o iii 5007A. This will allow the systemic velocity of each pn to be determined and will become the final data-set for mass modelling of the only large elliptical galaxy for which this massive study can be attempted. Catalogued globular clusters will also be included in each field for comparison with their kinematics and for determination of metallicity. Observing Mode: giraffe/Medusa, lr03 uves r580 Exposure time: 12h total (2 hrs per field, 6 fields) S/N to be Achieved: 8 in emission line for PN; 25-50 (depending on source brightness) for GCs Conditions : seeing 1 or less, clear coordinator :.
Rejkuba dynamical study of hst resolved Globular Clusters in ngc 5128 Objective: to determine the internal velocity dispersion in each of the hst resolved globular clusters, with some spatial kinematical information in the brightest ones, from high-resolution spectra at snr ranging from 20. Using the existing surface brightness profiles, we derive the mass/Luminosity ratios. One or two bundles could be devoted to fainter objects in order to check the possibility to extend such observation to closest clusters of galaxies. Observing Mode: giraffe/ifu hr12, lr5 Exposure time: 6000s in both setups S/N to be Achieved: 5-20 at hr, 14-50 at lr conditions : coordinator :. Blecha ngc 2808 - ra09:12:02.6 dec-64:51:47 Mass Loss in Globular ClusterRed giant Stars summary objective: to test mass outflow, hence mass loss scenarios, by measuring shifts of the main diagnostic (caii-k3, nad and h-alpha core line profiles) in 100 brightest red giant stars down from. Observing Mode: giraffe/Medusa hr02, hr12, hr14 uves r580 Exposure time: 4h S/N to be Achieved: 30 on caii (cont. 50 on nad and h-alpha lines Conditions: seeing.8", clear, grey coordinator :. Bragaglia geometric Distances of the galactic Globular Cluster ngc 2808 summary objective : to determine the geometric distance of the cluster via the comparison of proper motions and radial velocities to be measured for 1000 stars (such distance is expected to be derived to the. It will allow deriving an age with an error less than 1Gyr) and to investigate whether the peculiar morphology of its hb is due to the age (NGC2808 is a classical second parameter cluster) Observing Mode: giraffe /Medusa, hr09, hr05 uves r520 Exposure time:.
Number the Stars - wikipedia
Readme files, readme files submitted by each. Field-charts, all submitted finding charts. Flames sv daily Updates from advantages kueyen. Flames sv meetings and teams, flames science verification Summary - programs are grouped by main target. Lmc - ra05:12:14.8 dec-71:13:44, the Chemical Signature of Different Stellar Populations in the lmc. Summary, objective : to derive details of the chemical enrichment of the lmc by determining accurate abundances of different stellar populations: rgb, clump and lpv stars. Observing Mode: giraffe/Medusa HR14,HR13, hr10 combined with uves r580 and/or R860. Exposure time:.5h total (7.5h for help HR14, 6h for HR13, 6h for HR10) 1h for uves. S/N to be Achieved: rgb stars: 40-50/pix; Clump stars: 20/px; lpvs with uves: 20/res Conditions: seeing.0" coordinators :.
Flames instrument Package and Software. Important Notice (Feb 2003 All flames users (including members of the flames sv team) should carefully follow flames-related instructions provided on the. Phase2 Proposal Preparation web page. Both software tools and user-manuals have been revised for Period 71 observations. Phase2 material submitted for flames observations. Ob summary table (a list of all the submitted Observations Blocks). Ob break-down (the Observation Blocks Breakdown report from narrative P2PP).
the stars Hitori hitotsu no hoshi wo daki bokura wa aruiteru te to te tsunaidara seiza ni haru ne terasou mirai no hate made mo i believe. This is also the last ending theme to feature chibi animation. Flames science verification observations successfully took place on 24 Jan 24 - more than 5200 spectra have been collected! News, may 1, 2003: The few remaining frames (taken after the official flames sv run) have now been released. Programs selected for flames science verification. Lmc, centaurus a, nGC 2808, nGC 2243, mS 1054-03. Ngc 1310, orion, nGC 3585, useful Links, documents and tools. Preparing flames sv observations, instructions for flames sv phase2, only accessible to sv team members.
Terasou mirai no hate made. I believe, we're the stars, i believe, i'm right here, even in a maze of darkness. Let's call out to each other and keep moving. It's a road completely devoid of signs. But I have mom friends, shining brighter than light, are your eyes. We're the stars, each of us holding onto a star. We keep walking, with our hands linked, we'll become constellation.
Synopsis Sheet for Number the Stars - the literary link
We're the stars is the fourteenth ending summary theme of the, fairy tail anime; it is performed by, aimi terakawa. Characters in Order of Appearance, lyrics, tv version. Koko ni iru yo yami no meiro demo. Koe kakeai mae ni susumou. Mejirushi sae mienai michi, dakedo nakama ga iru, akari yori mo kagayaiteru. Kimi no hitomi ga aru, we're the stars Hitori hitotsu no hoshi wo daki. Bokura wa aruiteru, te to te tsunaidara seiza ni haru.