ABSTRACT Tax returns of both public and private corporations are protected from IRS disclosure by Internal Revenue Code §6103. Historically, most arguments against public disclosure of tax information were aimed at personal returns. This article evaluates arguments both opposing and favoring company-specific public disclosure of corporate tax returns, focusing on public companies and federal government contractors. Among reasons against disclosure are the fear that (1) it will add to, rather than reduce, confusion about corporate accounting and tax practices, (2) compliance will be reduced as companies seek to hide details of their revenue and expenses, and (3) proprietary information, including trade secrets, will be disclosed. Among reasons favoring disclosure are the (1) results of a national survey, (2) improvement of tax compliance, (3) limited value of privacy given that it does not cover disagreements with the IRS that wind up in court, (4) fiduciary responsibility corporations owe to the public, and (5) tendency of increased transparency to intensify public pressure for tax reform. Based on this analysis, it is argued that the benefits to be gained by increasing disclosure—especially encouraging tax reform—outweigh the objections raised, which either lack empirical basis or may be met with available remedies.

In its 2009 Taxpayer Attitude Survey, the U.S. IRS Oversight Board asked taxpayers: “Is it every American’s civic duty to pay their fair share of taxes?” Respondents strongly believe it is, with 70 percent claiming they “completely agree” and 25 percent that they “mostly agree.” On very few public issues is it possible to obtain 95 percent agreement and any such broad consensus should be met with skepticism. The near-unanimous response may mean no more than that people recognize that the functions of government must be paid for and that each person should pay a certain part. But in light of the reported $450 billion annual U.S. tax gap and evidence of declining taxpayer compliance, this paper raises questions about what taxpayers understand by “fair share” and the duty to which it gives rise. In this paper, I argue that the key to understanding how there can be a growing problem of tax cheating and yet a preponderance of taxpayers acknowledging a civic duty to pay their fair share, lies in taxpayers’ calculation of their fair share.

ABSTRACT Though tax complexity is a frequent topic of debate, the difficulty of defining or measuring what is meant by complexity is a stumbling block to tax simplification. Most measures of tax complexity are indirect or anecdotal. One dimension of tax complexity is addressed by the courts at an operational level—the final decision on the meaning of key words in a tax controversy. Faced with a word whose meaning is unfamiliar, unclear, or ambiguous, but critical to a tax dispute, the result may be a fork in the road. Is the term defined by statute, is it a term of art, or is it an ordinary English word? After exploring the courts' stated reliance on dictionaries in appropriate circumstances, the paper presents over 200 examples drawn from tax case law. Based on the courts' apparently increasing role as final arbiter of meaning in tax disputes, we suggest a general approach for slowing the pace of tax complexity.

Neutron and photon radiation survey records have been used to evaluate and develop a neutron to photon (NP) ratio to reconstruct neutron doses to workers around Hanford's single pass reactors that operated from 1945 to 1972. A total of 5,773 paired neutron and photon measurements extracted from 57 boxes of survey records were used in the development of the NP ratio. The development of the NP ratio enables the use of the recorded dose from an individual's photon dosimeter badge to be used to estimate the unmonitored neutron dose. The Pearson rank correlation between the neutron and photon measurements was 0.71. The NP ratio best fit a lognormal distribution with a geometric mean (GM) of 0.8, a geometric standard deviation (GSD) of 2.95, and the upper 95 th % of this distribution was 4.75. An estimate of the neutron dose based on this NP ratio is considered bounding due to evidence that up to 70% of the total photon exposure received by workers around the single pass reactors occurs during shutdown maintenance and refueling activities when there is no significant neutron exposure. Thus when this NP ratio is applied to the total measured photon dose from an individual film badge dosimeter, the resulting neutron dose is considered bounded.

This article examines the right of a 501(c)(3) organization to refuse an unrestricted cash donation, concluding that such right is generally illusory. If a charity disagrees with the donor on a moral issue, it may see nothing improper in turning away a would-be benefactor. When this occurs in the context of a 501(c)(3) organization, its exempt purpose requires looking beyond the conscience of the individuals making the decision. Specifically, the question of the organization's moral right to turn away funding occurs in the context of its pursuit of a legally sanctioned purpose. The organization's agreement with the IRS in seeking tax-exempt status produces a fiduciary responsibility with its stakeholders. These include donors, potential recipients of the organization's goods or services, taxpayers, and the government. Viewed from this perspective, turning down a gift, it is argued, is comparable to mismanagement in squandering scarce resources.

As the volume of gambling activity continues to expand in the U.S. the question of exactly what constitutes a gambling transaction for income tax purposes takes on increasing significance for taxpayers as well as tax practitioners. The law requires reporting gambling winnings separately from gambling losses. This separation raises the question of what constitutes a gambling winning which rests in turn on the definition of a gambling transaction. Is it a hand of blackjack or a day at the racetrack, a spin of a roulette wheel or the result from $100 placed in a slot machine, a roll of the dice or the night's poker results? Revenue recognition is not often an issue for individual taxpayers who report their income on a cash basis. The income recognition doctrine of constructive receipt reduces the direct control a cash basis taxpayer can exercise over the timing of the recognition of income. For the increasing number of taxpayers engaging in gambling activities, this doctrine may directly impact the amount of income they are required to recognize not merely because of the gambling income itself (some or all of which may be offset with a deduction for gambling losses) but as a result of this income's impact on adjusted gross income (AGI). While the exact definition of a gambling transaction, and thus the proper recognition of gambling income, is addressed by the I.R.S., it remains a contentious issue. However, when the doctrine of constructive receipt is extended to gambling revenue it clarifies the meaning of a gambling transaction and hence the proper amount of gambling income to be reported by taxpayers.

PurposeTo streamline the process of opportunity recognition and make it more effective by clarifying the meaning of opportunity and making its elements explicit.Design/methodology/approachClarifying opportunity is effected by providing a model and illustrating its effectiveness through application to examples and to SWOT (strengths, weaknesses, opportunities and threats) analysis.FindingsProvides support for the practical benefits of applying an explicit model for recognizing opportunity.Originality/valueThe model facilitates opportunity recognition by encouraging avoidance of common dead ends, including mistaking catalysts for opportunities, associating opportunities with negative conditions, equating options with opportunities and the circular process of defining opportunities in terms of strengths and weaknesses.

Measuring the collective performance of socially conscious mutual funds has so far presented a challenge because of diverse screening criteria. Because an investor is concerned about not supporting a company that sells tobacco does not imply the same investor feels as strongly about animal rights or child labor or gambling or alcohol. A systematic approach to measuring the results of socially responsible mutual funds directly investigates the performance of the companies or sectors that are screened out of the funds. The tobacco, alcohol, and gambling sectors outperformed the S&P 500 over 11 years, with lower coefficients of variation than the benchmark.

Managing expectations in a business ethicscourse is important and a key place to begin iswith a definition of a moral problem. Untilrecently I would explain, using moral terms,good and bad, right and wrong, duty or obligation or theircognates, what a moral problem is generally andthen what it may be in business. However Ifound that using familiar terms with vague orambiguous meanings to define the subject matterof the course counterproductive. What Irequired is a means of explaining to thebeginning student what a moral problem iswithout relying on the prior associations andmeanings of the term moral that thestudent brings to the discussion. In recentyears I realized that what I wanted, as astarting point for the business ethics course,is a definition of moral problem thatdoes not use specifically moral terms i.e.good, bad, right, wrong, duty. For pedagogicalreasons, I wanted a definition that suppliesthe criteria for determining whether a givenproblem is a moral problem or not without usingcommon moral terms. This paper reviews thetreatment given to the concept of a moralproblem in a number of standard business ethicstexts and then presents a working definitionthat does not rely on the use of specificallymoral terms. The definition is then critiquedfor limitations and weaknesses.

This paper presents the results of and conclusions from a survey of 2,830 college and university undergraduate business and philosophy departments regarding their business ethics offerings. The impetus for this survey included seeking a better understanding of the problems for which business ethics courses are the solution. It was proposed that, if we knew what it is that professors teaching business ethics believe they are teaching—not in terms of content or methods, but in terms of what criteria they are using to assess students’ achievement of the course objectives—we would have a better understanding of what issues business ethics attempts to resolve. The survey focused on ranking six possible assessment criteria drawn from the literature on teaching business ethics.In addition to disclosing the specific survey results, the paper draws conclusions based on the fact that there are statistically significant differences between the rankings assigned to the six assessment criteria by business professors as contrasted with philosophy professors. The results of the survey indicate that there is more uniformity expressed in the responses by the philosophy professors teaching business ethics than by the business professors.

This paper presents the results of and conclusions from a survey of 2,830 college and university undergraduate business and philosophy departments regarding their business ethics offerings. The impetus for this survey included seeking a better understanding of the problems for which business ethics courses are the solution, it was proposed that, if we knew what it is that professors teaching business ethics believe they are teaching-not in terms of content or methods, but in terms of what criteria they are using to assess students' achievement of the course objectives-we would have a better understanding of what issues business ethics attempts to resolve. The survey focused on ranking six possible assessment criteria drawn from the literature on teaching business ethics.In addition to disclosing the specific survey results, the paper draws conclusions based on the fact that there are statistically significant differences between the rankings assigned to the six assessment criteria by business professors as contrasted with philosophy professors. The results of the survey indicate that there is more uniformity expressed in the responses by the philosophy professors teaching business ethics than by the business professors.

Departments of Dermatology and Plastic Surgery Harvard Medical School Beth Israel Hospital 330 Brookline Avenue Boston, Mass. 02215

Survey of racial terminology employed in southern Africa since 1652 is discussed

Axions thermally emitted by a neutron star would be converted into x rays in the strong magnetic field surrounding the star. The present observational limit of pulsed x rays from the Vela pulsar (PSR 0833-45) is not small enough to bound the axion mass. An increase in x-ray sensitivity by a factor of ${10}^{4}$ would constrain the axion mass ${M}_{a}$3\ifmmode\times\else\texttimes\fi{}${10}^{\mathrm{\ensuremath{-}}3}$ eV if the core is nonsuperfluid and at temperature ${T}_{c}$\ensuremath{\sim}2\ifmmode\times\else\texttimes\fi{}${10}^{8}$ K. This would improve the limits ${M}_{a}$\ensuremath{\lesssim}4\ifmmode\times\else\texttimes\fi{}${10}^{\mathrm{\ensuremath{-}}2}$ eV from neutron-star cooling and ${M}_{a}$1\ifmmode\times\else\texttimes\fi{}${10}^{\mathrm{\ensuremath{-}}2}$ eV from red-giant evolution. If the core is superfluid throughout, a factor of ${10}^{5}$ in sensitivity would be needed. A search for modulated hard x rays from PSR 1509-58 or other young pulsars is suggested. A limit on pulsed hard x rays 5\ifmmode\times\else\texttimes\fi{}${10}^{\mathrm{\ensuremath{-}}7}$ photons/${\mathrm{cm}}^{2}$ sec from a very young hot (${T}_{c}$\ensuremath{\sim}7\ifmmode\times\else\texttimes\fi{}${10}^{8}$ K) pulsar within the Galaxy could set a firm bound on the axion mass, since neutron superfluidity is not expected above this temperature.