M26 Pershing Tank in World War II

The M26 Pershing was a heavy tank developed for the U.S. Army during World War II. Conceived as a replacement for the iconic M4 Sherman, the M26 suffered from an extended design and development process as well as political infighting among the U.S. Armys leadership. The M26 arrived in the final months of the conflict and proved effective against the latest German tanks. Retained after the war, it was upgraded and evolved. Deployed during the Korean War, the M26 proved superior to the tanks used by Communist forces but struggled at times with the difficult terrain and suffered from various issues with its systems. The M26 was later replaced by the Patton series of tank in the U.S. Army. Development Development of the M26 began in 1942 as production was beginning on the M4 Sherman medium tank. Initially intended to be a follow-on for the M4, the project was designated T20 and was to serve as a test bed for experimenting with new types of guns, suspensions, and transmissions. T20 series prototypes employed a new torqmatic transmission, the Ford GAN V-8 engine, and the new 76 mm M1A1 gun. As testing moved forward, problems emerged with the new transmission system and a parallel program was established, designated T22, which utilized the same mechanical transmission as the M4. A third program, the T23, was also created to test a new electric transmission which had been developed by General Electric. This system quickly proved to have performance advantages in rough terrain as it could adjust to rapid changes in torque requirements. Pleased with the new transmission, the Ordnance Department pushed the design forward. Possessing a cast turret mounting the 76 mm gun, the T23 was produced in limited numbers during 1943, but did not see combat. Instead, its legacy proved to be its turret which was later utilized in 76 mm gun-equipped Shermans. Panther Tank. Bundesarchiv, Bild 101I-300-1876-02A A New Heavy Tank With the emergence of the new German Panther and Tiger tanks, efforts began within the Ordnance Department to develop a heavier tank to compete with them. This resulted in the T25 and T26 series which built upon the earlier T23. Devised in 1943, the T26 saw the addition of a 90 mm gun and substantially heavier armor. Though these greatly increased the tanks weight, the engine was not upgraded and the vehicle proved underpowered. Despite this, the Ordnance Department was pleased with the new tank and worked to move it towards production. The first production model, T26E3, possessed a cast turret mounting a 90 mm gun and required a crew of four. Powered by the Ford GAF V-8, it utilized a torsion bar suspension and torqmatic transmission. Construction of the hull consisted of a combination of castings and rolled plate. Entering service, the tank was designated M26 Pershing heavy tank. The name was selected to honor General John J. Pershing who had founded the U.S. Armys Tank Corps during World War I. M26 Pershing DimensionsLength: 28 ft. 4.5 in.Width: 11 ft. 6 in.Height: 9 ft. 1.5 in.Weight: 41.7 tonsArmor ArmamentPrimary Gun: M3 90 mmSecondary Armament: 2 Ãâ€" Browning .30-06 cal. machine guns, 1 Ãâ€" Browning .50 cal. machine gunArmor: 1-4.33 in.PerformanceEngine: Ford GAF, 8-cylinder, 450–500 hpSpeed: 25 mphRange: 100 milesSuspension: Torsion BarCrew: 5 Production Delays As design of the M26 came to completion, its production was delayed by an ongoing debate in the U.S. Army regarding the need for a heavy tank. While Lieutenant General Jacob Devers, the head of U.S. Army forces in Europe advocated for the new tank, he was opposed by Lieutenant General Lesley McNair, commander Army Ground Forces. This was further complicated by Armored Commands desire to press on the M4 and concerns that a heavy tank would not be able to use the Army Corps of Engineers bridges. With the backing of General George Marshall, the project remained alive and production moved forward in November 1944. While some claim that Lieutenant General George S. Patton played a key role in delaying the M26, these assertions are not well supported. Ten M26s were built in November 1943, with production escalating at the Fisher Tank Arsenal. Production also commenced at the Detroit Tank Arsenal in March 1945. By the end of 1945, over 2,000 M26s had been built. In January 1945, experiments began on the Super Pershing which mounted the improved T15E1 90mm gun. This variant was only produced in small numbers. Another variant was the M45 close support vehicle which mounted a 105 mm howitzer. An M26 Pershing of A Company, 14th Tank Battalion, is transported aboard a pontoon ferry across the Rhine on March 12, 1945. National Archives and Records Administration World War II Following American losses to German tanks in the Battle of the Bulge the need for the M26 became clear. The first shipment of twenty Pershings arrived in Antwerp in January 1945. These were split between the 3rd and 9th Armored Divisions and were the first of 310 M26s to reach Europe before the end of the war. Of these, around 20 saw combat. The M26s first action occurred with the 3rd Armored on February 25 near the Roer River. Four M26s were also involved in the 9th Armoreds capture of the Bridge at Remagen on March 7-8. In encounters with Tigers and Panthers, the M26 performed well. In the Pacific, a shipment of twelve M26s departed on May 31 for use in the Battle of Okinawa. Due to a variety of delays, they did not arrive until after the fighting had ended. Korea Retained after the war, the M26 was re-designated as a medium tank. Assessing the M26, it was decided to rectify the issues of its under-powered engine and problematic transmission. Beginning in January 1948, 800 M26s received new Continental AV1790-3 engines and Allison CD-850-1 cross-drive transmissions. Along with a new gun and host of other modifications, these altered M26s were redesignated as the M46 Patton. USMC M26 Pershing tank advancing in Korea, September 4, 1950. National Archives and Records Administration With the outbreak of the Korean War in 1950, the first medium tanks to reach Korea were a provisional platoon of M26s dispatched from Japan. Additional M26s reached the peninsula later that year where they fought alongside M4s and M46s. Though performing well in combat, the M26 was withdrawn from Korea in 1951 due to reliability issues associated with its systems. The type was retained by U.S. forces in Europe until the arrival of new M47 Pattons in 1952-1953. As the Pershing was phased out of American service, it was provided to NATO allies such as Belgium, France, and Italy. The Italians used the type until 1963.

Evaporation Definition and Examples

Evaporation is the process by which molecules undergo the a spontaneous transition from the liquid phase to the gas phase. Evaporation is the opposite of condensation. For evaporation to occur, molecules in a liquid must be near the surface, must be moving away from the body of the liquid, and must have enough kinetic energy to escape the interface. When molecules do escape, the average kinetic energy of the remaining molecules is lowered. This lowers the temperature of the liquid and is the basis for the phenomenon of evaporative cooling. Example The gradual drying of damp clothes is caused by the evaporation of water into water vapor. Source Silberberg, Martin A. (2006). Chemistry (4th ed.). New York: McGraw-Hill. pp. 431–434. ISBN 0-07-296439-1.

Motivation Working In Groups Education Essay Free Essays

string(100) " and the scheme adopted by the pupil is to make at the most what is required to accomplish his end\." Abstraction The planetary competitory environment is witnessing a new displacement where more and more companies are forming their activities and undertakings around groups. Bing able to work efficaciously in a group is now considered a important demand for any employee. This write up inside informations my motive behind fall ining a Masters class in direction at the Bangor Business School and how this is assisting me to smooth my accomplishments as an effectual group member and a future director. We will write a custom essay sample on Motivation Working In Groups Education Essay or any similar topic only for you Order Now This piece of work besides identifies assorted issues faced when working in groups and simple solutions that can be applied to antagonize these booby traps to maximise end products. MOTIVATION FOR JOINING A POSTGRADUATE PROGRAM IN MANAGEMENT The undergraduate plan in Commerce at Bishop Heaber College Trichy, India introduced me to a broad scope of subjects in my nucleus topic such as economic sciences, statistics and mathematics. The commercialism course of study non merely inculcated a high grade of job resolution and analytical accomplishments in the nucleus field but besides gave me a opportunity to briefly explore other practical concern spheres such as direction, finance, selling, accounting and jurisprudence. These subjects are extremely relevant in the current economic scenario and it is really interesting to look into how the interplay of assorted forces thrusts planetary growing. What fascinated me most was the fact that many of the theoretical subjects in direction have profound practical public-service corporation and when applied to assorted jobs these guarantee of import procedure and merchandise betterments. In order to carry through my dream of going a high-tech concern adviser, I decided to fall in a postgraduate plan in Management at a reputed university that would supply me with ample chances in footings of growing, personally every bit good as professionally. Harmonizing to McClelland ‘s Theory of Needs motive depends on three demands – Accomplishment, power and association ( McClelland, 1961 A ; 1975 ) . These 3 factors were instrumental in actuating me to fall in a postgraduate plan and work towards accomplishing my ends. THE BANGOR BUSINESS SCHOOL: A GLOBAL PLATFORM The following challenge that I faced was to calculate out a university that would run into my criterions and demands and would turn out cardinal to my success in future enterprises. After a thorough research, I zeroed down on the Bangor Business School at the Bangor University. Harmonizing to Clayton Alderfer ‘s ERG Theory, being, relatedness and growing are the three chief factors that motivate people for fall ining an organisation. My determination of fall ining the Bangor University was based on these three factors as this university provides personal attending to pupils, offers chances that pupils can associate to and nowadayss ample infinite to turn ( Alderfer, 1969 ) . The Bangor concern school provides a overplus of classs in direction with a extremely trained staff and coactions worldwide with the industry supplying first-class future chances. The fact that this concern school has been late rated by the Research Assessment Exercise ( RAE ) as the best in UK for accounting and finance farther strengthened my determination of fall ining this university ( Bangor, Homepage, 2010 ) . In recent yesteryear, the university staff was responsible for transporting out extremely acclaimed consultancy undertakings for authorities and non-government organisations with assorted publications in the prima diaries. The Bangor concern school provides abundant chances for heightening and developing competences in direction. Besides, in order to go a successful adviser I require custodies on experience and cognition of planetary concern, foreign markets and competition with a thorough apprehension of planetary forces and concern schemes. Bangor, through its coaction with foreign companies and universities provides sufficient exposure in the planetary domain, both practically every bit good as technically. Students AT BANGOR BUSINESS SCHOOL Another factor that attracted me towards the Bangor concern school apart from the module and installations was the pupils. As the college undertakes merely a limited figure of extremely qualified pupils who are selected after stiff competition, quality of pupils is the kernel of this university. The chief advantages offered by this layout include: Fewer figure of pupils enrolled guarantee that an first-class resonance is developed with all the members of the class. This helps in interchanging rich cognition and expertness from assorted subjects such as humanistic disciplines, commercialism, jurisprudence, scientific discipline, concern disposal, selling, etc. amongst different pupils. The familiarity, good will and contacts built during the continuance of the class prove to be really effectual and of import in the long tally when different pupils join different industries at assorted profiles. These pupils have varied positions and backgrounds and sharing this enormously helps in bettering any professional. Therefore, interacting with this creme de la creme was a large motive for fall ining the Bangor University. APPROACHES TOWARDS LEARNING Determining an appropriate and contributing attack towards larning is indispensible to the procedure of deriving cognition. Harmonizing to Biggs A ; Telfer ( 1987 ) , the chief attacks undertaken by pupils comprise of two elements – Motivation and Strategy. Based on this, he identified three chief attacks adopted by pupils. These were the Surface Approach, the Deep Approach and the Achieving Approach. Surface Approach: In the Surface Approach, positive and negative extrinsic motivations play a critical function and pupil ‘s scheme is to try the least to go through a topic. In the procedure he renders himself inefficient of understanding the significance of what he has learned and the interplay of factors because the motivation is superficial and he has no personal involvement in what he is making. Deep Approach: In the Deep Approach, motivation is an intrinsic wonder to larn things and the scheme undertaken by the pupil is one of personal committedness towards larning. In the procedure he comprehends and understands things in the best possible mode, attempts to co-relate things learned with past experiences and accomplishes the chief undertaking of analyzing. Achieving Approach: In the Achieving Approach, the motivation is to accomplish a peculiar end such as high classs and the scheme adopted by the pupil is to make at the most what is required to accomplish his end. You read "Motivation Working In Groups Education Essay" in category "Essay examples" MY Approach TOWARDS LEARNING During my full pupil life I have ever strived towards deriving a deep cognition of each topic that I studied. In the competitory universe that a professional faces one time that he comes out of the college, a strong foundation is required if he wishes to boom and turn. Hence, when I joined the Bangor University my chief motive was to construct a strong and deep apprehension of assorted topics, variables and subjects of direction. Influence OF THE BANGOR BUSINESS SCHOOL ON MY APPROACH TOWARDS LEARNING In 2001, Biggs described two chief influences that shape a pupil ‘s attack towards larning – Personal factors and Teaching. These are described below: Personal factors such as background, upbringing or personality may hold a positive or negative consequence on the pupil and may motivate him towards developing a Surface Approach or a Deep Approach. Teaching: Conventional learning methods such as everyday scrutinies, clip force per unit area, taging strategies, detainment, etc. lead pupils towards developing a Surface Approach of larning. On the other manus, newer learning methods such as instance surveies, activities, tutorials, job resolution, flexible rating systems, etc. promote pupils towards developing a Deep Approach. At Bangor, the module believes in an synergistic instruction manner where the pupil is free to inquire inquiries and is encouraged to believe out of the box. In fact the techniques employed have molded assorted pupils from being Surface attacks to Deep attacks. This procedure has been accelerated by advancing student-student interactions that result in an exchange of expertness and in bend actuating pupils to travel for an in-depth analysis of assorted jobs and issues. In short, the unique and latest learning methods employed at Bangor have helped direction pupils in developing a strong apprehension of assorted direction related subjects such as Problem Solving and Decision Making, Planning, Delegation, Internal Communications, Meeting Management, Leading, Coordinating and Controlling, Pull offing Self, Managing Stress, etc. ( McNamara, 2010 ) . These methods provide a alone environment where the pupils contribute towards the growing of each other therefore maintaining one and all motivated. Simultaneously, the university achieves the primary end of instruction by heightening the acquisition ambiance of pupils and by increasing the efficiency of the module. UNITY IN DIVERSITY As discussed earlier, Bangor demonstrates a broad scope of diverseness by uniting different people from different parts with different academic backgrounds as one large group. As a portion of the MBA course of study, many times pupils are required to be grouped harmonizing to activities, instance surveies or undertakings assigned to the category. This brings the subject of working in groups. Harmonizing to Robbins ( 2004, pp:219 ) : â€Å" A Group is defined as two or more persons, interacting and mutualist, who have come together to accomplish peculiar aims † . Working in groups can be either pleasant or hard or at times both. On the brighter side, uniting people with heterogenous backgrounds and experiences ensures best consequences in footings of value add-on to the batch. Students demonstrate a high degree of originative thought, solutions design and job work outing guaranting better end products. The kineticss achieved by this theoretical account guarantees a healthy ambiance within the campus and pupils staying positively competitory. POSITIVE ASPECTS OF WORKING IN GROUPS In Management classs, pupils are divided into groups to accomplish assorted motivations which in bend help them in deriving a competitory border when they venture out in the industry. A individual who works good in a group is in all possibility traveling to be an first-class squad worker when he joins an organisation. Assorted positive results achieved by working in groups are described below: When pupils work in groups they draw on each others knowledge and expertise to accomplish better consequences. This is due to the fact that a multiple sentiment is ever better than a individual sentiment as it shows heterogeneousness and avoids prejudice. Group working achieves best consequences for rating studies such as instance studies, reappraisals and reviews, research undertakings such as those that entail primary and secondary research and little undertakings that involve an statement such as a argument. Students working in groups besides make the best of the available strengths within the group. For e.g. in a written undertaking, one of the members who has an first-class bid on vocabulary can compose the paper whereas other who has an expertness in the linguistic communication can proofread. Working in groups makes pupils responsible as they work coherently to accomplish a common undertaking and in the procedure maintain actuating each other to execute better. While working in groups there is a least possibility for members to stall. Group working ensures that single manners ever come to the head supplying enhanced consequences. Press FACTORS ON GROUP WORKING Group working is governed by assorted pressing factors such as efficiency of members, degree of struggle, external conditions, procedures, internal communicating, etc. These factors give rise to assorted issues within the group ( Goodman, 1987 ) . Group work is seldom perfect and one is expected to meet a broad scope of issues and jobs when working in groups. For any direction pupil to be effectual it is really of import that he uses solutions design and advanced schemes for antagonizing these issues. What remains indispensable is the fact that whatever 1 does, he should non ache or pique other group members. Few issues associated with working in groups along with executable solutions will be discussed in the undermentioned paragraphs. Working IN GROUPS: ISSUES A ; SOLUTIONS I ) Disagreement Disagreement and following a collaborative working manner are the biggest issues when working in a group. Each person in the group should understand that the basic thought of the course of study behind transfusing a collaborative working manner is the fact that thoughts will be challenged to accomplish better consequences and a struggle is non ever bad ( Schellhardt, 1994 ) . There are opportunities that other members of the group might come up with thoughts that are right or more relevant and can be supported by grounds. In order to stay competitory in such a scenario one should promote dissension to measure the strength of 1s ain thoughts and to research other possible options. A collaborative working manner should be promoted in the group to antagonize dissension. Collaborative manner has assorted paradigms associated with it. These include stating non merely what to make in the group but besides activities required for carry throughing a peculiar undertaking i.e. how to accomplish desired consequences. Collaboration is most fruitful when a certain degree of formality is introduced in the group behaviour such as everyday meetings and advancement sheets and by maintaining the group ‘s involvement before personal 1s. Another step to antagonize dissension is to be ready to compromise. This means that each member of the group should be ready to listen and suit each others sentiment and forfeit or modify his ain theories in the visible radiation of cognition and grounds. Encouraging dissension, as discussed above, is really effectual but what should be understood is the fact that groups that merely differ do non stay functional. Therefore, it is really of import to equilibrate the 2 forces of dissension. As per Robbins ( 2004 ) a working group is non an unorganised crowd but should hold a construction and most significantly a leader or a captain or a go-between. Therefore, a go-between or chair individual can be assigned for each meeting who will listen to all the parties and come up with concluding indifferent recommendations. All groups have specific norms that are established early to guarantee smooth operation ( Hackman, 1992 ) . Discussion regulations such as no personal onslaughts can be decided early in the procedure. Group behavior encourages people to develop a critical attack towards inquiries which proves to be an advantage in existent universe puting where an person is confronted with assorted pressing issues and jobs. II ) DIVISION OF WORK Division of work Division of work and duties is indispensible to the success of working in groups. Undertakings should be divided in such a manner that all resources are adequately utilised without over burthening any specific person. The existent undertaking can be broken down into smaller sub-tasks and each sub-task can be assigned to one individual. Care must be taken to guarantee that sub-tasks should be divided harmonizing to single strengths. For e.g. a individual good at proofreading can be assigned for proofreading and one good at forming should be assigned to forming informations and concluding end product. Furthermore, interpersonal accomplishments are a deciding factor for high public presentation and members should show and larn these from each other to better their competences ( Stevens A ; Campion, 1994 ) . Therefore, to maximise the use of resources work should be delegated harmonizing to the strengths and expertness of group members. III ) SOCIAL Idleness Covering with Slackers is another issue in group working. This phenomenon called as Social Loafing ( Comer, 1995 ) refers to the inclination of people to work less when working in groups. Normally persons on a individual undertaking are uniformly graded hence go forthing a large room for one or more members to go dawdlers. To cover with this state of affairs, regulations should be laid down at the start itself. These can be simple penalties such as if a member does non go to a meeting without any specific ground he would purchase a Burger for everyone in the group to harsh 1s such as non including the name of the individual on the concluding study. Usually group members end up making excess work because they do non take shirkers to undertaking and do non talk their head. On the contrary, such sentiments and issues should be flagged at the earliest in the group. IV ) RESPECT FOR INDIVIDUAL Another chief issue associated with working in groups is keeping regard for persons. The image becomes hard when one or more members in the group see themselves superior and smarter than others. This is a unsafe attitude that may do clash within the group. Besides there is a opportunity where persons may believe that they would hold learnt better if they had worked separately on the subject. Researchs have demonstrated that group working is more efficient in doing better quality and speedy determinations when compared to single working ( Cooke A ; Kernaghan, 1987 ) . It is besides of import to promote members to discourse their strengths and failings at the first session itself so that they can be best utilised. Sharing of ideas by and large consequences in coherence within a group as people feel nearer to each other. Group members should be encouraged to develop and heighten their ability to LISTEN. Group works best when all members are ready to listen to each other with an unfastened head. Furthermore, in a campus environment where pupils come from different states and civilizations, something which is acceptable in one civilization might non be the same in another ( Axtell, 1991 ) . Therefore, regard for persons, their civilizations and values is indispensable to the success of any group. V ) Communication Timely communicating on all undertaking and single related affairs is paramount to the success of any group. Unable to run into at distinct clip or topographic point can take to perturbations in the smooth running of a group. Regular communicating should be maintained in the signifier of regular meetings to be held at a stipulated clip agreed amongst the group members. Here, persons can voice their findings on assorted subjects every bit good as flag their personal jobs if any. Other options such as electronic mails, telephones, confab suites, couriers, etc. may be used if in instance one-to-one treatments can non be planned at all. One of the members can be assigned to enter proceedingss of the meeting and can go around the meeting notes to everyone. This formalizes the procedure of communicating and makes certain that everyone in the group is on the same platform. Besides it is easier for the members to look back on the notes and see if they are on the mark and have achieved what w as decided as per agenda. VI ) TIME MANAGEMENT Inefficient clip direction besides causes a batch of jobs if things are non achieved as distinct. Therefore to avoid clip lags the best attack is to hold pre-agreed mileposts for the undertaking that can be converted into Gantt charts. It is a misconception that working in a group takes lesser clip. In fact, working in a group can be really clip devouring due to encephalon storming, developing understanding on a subject, collating information, alterations and proofreading, etc. Thus, group work should ne’er be considered as less work in lesser clip. It is besides of import to use meeting clip expeditiously to avoid slowdown subsequently on. To accomplish this, the docket of the following meeting can be decided in the current one itself ; all members should come prepared for the meeting ; go-between can direct a reminder through electronic mail or phone before for the approaching meeting ; go-between or chair individual should be rigorous about the timelines. Decision: MBA A ; BEYOND To sum up, prosecuting a Masters grade in Management for me is non merely a tool to accomplish position, richness and wealths but a ladder to understand and research assorted spheres of direction. The chief motive behind trailing this plan is to play with assorted direction patterns in order to understand the interplay of factors and to larn ways of using latest theories of direction to pattern. This will assist me in going an first-class director by steering my accomplishments to plan efficient and advanced concern solutions. Continuous chase for wisdom has made me look up to the cognition that I already had and has farther motivated me to hone my accomplishments. The Bangor Business School has provided me an first-class chance to carry through my dream by fall ining this class and deriving sufficient in footings of proficient accomplishments, interpersonal accomplishments and contacts. This concern school has non merely equipped me with a deep cognition of the class stuff but is determining me to be an effectual scholar and hearer. Assorted direction attacks and rules that I am larning in this class such as working in groups will fit me better to accommodate easy when I join the existent universe of concern. My love for direction patterns will do me take up challenges whole heartedly. APPLICATIONS OF THE CURRENT TOPIC This organic structure of work can be used by pupils to understand the importance and kineticss of working in groups. Furthermore, simple solutions proposed can be easy adopted and implemented by one and all to maximise end products when working in groups. How to cite Motivation Working In Groups Education Essay, Essay examples

Foundation of Taxation Law Residency and Taxpayers

Question: Describe about the Foundation of Taxation Law for Residency and Taxpayers. Answer: 1. Issue By considering the given situation and the facts regarding English resident Fred who has arrived in Australia with his wife to discharge his professional obligation, the pivotal aim is to opine on the underlying tax residency status for him by considering the relevant statutes. Rule For the determination of tax residency of individual taxpayers, TR 98/17 prescribes the following four residency tests to be used on an annual basis by the taxpayers (Nethercott, Richardson Devos, 2016) Domicile Test This is used only for residents of Australia since one of the pre-conditions is that the given taxpayer under assessment should have Australian domicile. Additionally, the location of permanent residence for the taxpayer should not lie outside Australia (Barkoczy, 2015). Superannuation Test This is used only for tax residency determination of Australian government employees who tend to serve abroad. The essential condition that needs to be met is contribution to select superannuation scheme (Coleman, 2011). 183 day Test This is used only by foreign resident currently in Australia. Two conditions need to be satisfied as listed below (CCH, 2014). A stay period of minimum 183 days in Australia for the taxpayer. Taxpayers willingness to settle in Australia going ahead. Resides Test The following factors are considered pivotal for determination of tax residency of foreign residents (Gilders et. al., 2015). Nature of ties in the professional and personal field that the taxpayer maintains in Australia. Extent of visits to the country of origin along with the underlying intent and duration. Extent of significance of the purpose with which taxpayer has come to Australia. Application In case of Fred, owing to his foreign domicile and employment with England based employer, domicile test and superannuation test are ruled out. Thus, the remaining tests need to be performed for Fred. 183 day test The condition regarding minimum stay period of 183 seems to be adhered to by Fred owing to 11 month stay. However, the intention to settle in Australia seems lacking as Fred has refrained from making any investment in fixed asset in Australia and continues to hold the home in England. Thus, due to the latter condition not met, the test is failed. Resides Test- The test is passed considering the following factors. Employment of 11 months which is still expected to continue further is a significant purpose to visit Australia. Fred has not gone to England even once during the 11 month period and also his behaviour during stay in Australia is not different from that exhibited in England. Conclusion Based on the above arguments, it is apparent that Fred manages to satisfy a residency test and hence is Australian tax resident. 2. Californian Copper Syndicate Ltd v Harris (Surveyor of Taxes) (1904) 5 TC 159 The Californian Company acquired a land containing a copper mine but could not commence the mining operation on the land as they were short in the working capital. The investors knew about the fact that they would not be left with the requisite fund, after spending such a huge amount for acquiring the mine before making the decision to buy land. Company sold the mine to other competitor mining company and received shares in that company as compensation. The saleable value of the acquired shares was high and the derived profit was much higher than the amount they used for acquiring of the mine. The company made claims that it was only shifting of one asset with another and thus, they would not be liable for income tax on the received gains (Sadiq et. al., 2016). The tax commissioner pronounced that the gains from the shares would be assessable for taxation. Company appealed in the court against the verdict of the tax commissioner. The court believed that the gains from the liquidation of the companys ownership would be assessable for taxation as profit intent was present before the purchase of land and mining use was never intended. Hence, the transaction was of isolated nature with the profit intention on the part of the investors (Deutsch et. al., 2016). Scottish Australian Mining Co Ltd v FC of T (1950) 81 CLR 188 The Scottish Mining Company bought a mine with the focus of coal mining. The company constantly mined the land and the process was continued for multiple years stretching into decades. It was observed that the coal content in the land was exponentially decreasing and after some time the land could not be mined further. Therefore, the mining operation was closed on the land and it was of no use to conduct any other business activity due to amorphous structure. Company liquidated the mine, after undertaking several requisite development actions like roads, plots, parks, school, and hospital and water supply and so on. Considerable profit was received by the investors from the mine land liquidation. The matter landed into court, where it was advocated that the company performed the central work i.e. coal mining for years and when the land was of no use then only, the investors liquidated the land. It was also stated on behalf of the investors that the land development was not with the i ntent of maximizing the profit. The activities were requisite to convert the amorphous land into residential place. Hence, it was just realisation of the asset in the most effective manner possible. The court accepted the claim of the company and announced that the profit would not be assessable as it was realisation of the asset (Jade, 2016). FCT v Whitfords Beach Pty Ltd (1982) 150 CLR A beach front land was purchased by the given company, which was used for drying of the fishing shacks and other fishing related equipment. The owners decided to alter the fishing business and finally liquidated the shares of the company to three companies. The basic functions of the companies were land development and land trading for higher profit. These companies wanted a beachfront land property and thus, bought the fishing company with the main focus of deriving the profits from the beach front land. Companies modified the old article of association of the company. Plethora of land development activities were started on the land and finally, the newly constructed plots were sold and caused sizable profits. The court opined that the companies acquired the fishing company especially for the beach front land so that the beach side land could be developed and then liquidated for higher gains, same had been introduced in the article of association of the company. Therefore, these bus iness actions of the taxpayers caused the tax accessibility on the received proceeds under the ordinary income scheme of ITAA, 1936 (CCh, 2016a). Statham Anor v FC of T 89 ATC 4070 A piece of deceased estate farm land was given to Statham Anor, which was originally used for agriculture. A small cattle firm was started by the taxpayer on this land. However, during its initial stage the business became abortive and caused reasonable loss to the taxpayers. They were also facing financial struggles and required funds to support even their living expense. They did not have enough funds to commence any other business on the land and thus, subdivided the farmland into smaller plots and without advertising, liquidated the plots to prospective buyers. The taxpayers articulated that the monetary issues forced them to sell the farm land and thus, the gains should not be assessable for tax. The court agreed with the request made and passed the judgement that the land liquidation resulted due to the failure of the business and due to the shortage of funds to sustain the livelihood. There were neither the land development activities nor the business action on the part of th e taxpayers. Therefore, the gins would be termed as capital receipts and not assessable for income tax (CCh, 2016b). Casimaty v FC of T 97 ATC 5135 The taxpayer received a part of farm land from his father for conducting the farming business. He undertook sizable loan from the bank basically for dual purpose, for fencing around the land and to start the farming. The production from the farming was not much, due to drought in the same year and caused insignificant income to the taxpayer. The taxpayers had taken sizable loan at high interest rate, which was increasing debt related liabilities on him. High financial debt and low income from the farming caused high stress and weakened the health of the taxpayer. In order to resolve the issues, he decided to liquidate the land. Since, he did not want to liquidate the whole farm land and took more loans to make subdivision on the land. A huge block of the land was sold and the earned gains were consumed to repay the loan amount. Moreover, the remaining block of the land was used for farming by the taxpayer. The honourable court passed the verdict that the liquidation of the portion of the land would be categorised under realisation of the capital asset as there was no profit intention of the taxpayer behind the sale. Additionally, the taxpayer continued his traditional farming occupation on the remaining block of the land. Therefore, the gains would be considered as capital income and non-assessable for income tax (CCh, 2016c). Moana Sand Pty Ltd v FC of T 88 ATC 4897 The given company purchased sand mine to carry the sand mining business. The essential work permits were also acquired from the municipal corporations by the company. After some time of steady mining, the sand reserves were finished and further sand mining could not be performed. Hence, the company decided to sell off the mine land. In regards to maximize the sale revenue, several value enhancement actions were carried on the land like plots, roads, parks, hospitals, water supply, churches, sewerage plant unit and other requisite service were installed. These developed plots were sold to premium buyers and derived reasonably high revenues. Company made various claims that the land was of no use and thus utilized by selling (Coleman, 2011). The court overruled the claims of the company and believed that the property was acquired for sand extraction not for land business. However, company invested a sizable amount just to develop the land. The instalment of the services on the land was conducted so that higher revenues could be generated. Therefore, the revenues from sale would be assessable for the income tax (Barkoczy, 2015). Crow v FC of T 88 ATC 4620 Any repetitive course of business action would cause ordinary income that would be chargeable for income tax in the accordance of the Income Tax Assessment Act, 1936. The taxpayer Crow had performed the same action as he acquired a five block land from borrowed amount and commenced the farming for very limited time and then started development actions on the bought land. Fifty one sub-blocks were formed from this five block land and sold to retail customers. This activity was continued for many years as new land was bought and then sold to buyers at higher price after carrying some development activities. The central business strategy of the taxpayer was to buy the land, make subdivision and finally sell to buyers. The commissioner stated that the business motive of the taxpayer would be considered for tax accessibility. The taxpayer claimed that he sold the land in regards to repay the loaned amount. The matter was taken to court, where court rejected the claims and passed the verdi ct that the repetitive action of land trading and division was clear sign of carrying the land trading business. Hence, the proceeds from the sale would be assessable for income tax (CCh, 2016d). McCurry Anor v FC of T 98 ATC 4487 The taxpayers acquired a land parcel, which already had few old unstructured buildings. Three townhouses were constructed on the purchased land by availing borrowed funds. Advertisement was also made for the sale of the townhouse. Irrespective of this advertisement, the townhouses could not be sold. They decided to keep the townhouses for the time being and sold when they would receive the expected amount. Moreover, one townhouse was used for personal residence by the taxpayers. After a year, the townhouses were sold as per their expected profits. It was cited on behalf of the taxpayers that the gains should not be considered under the outlines of the ordinary income of income tax. The honourable court passed the decision that the arguments of the taxpayers were not valid. Since, their intention was to derive higher gains, and with the same, they constructed new townhouses. Additionally, they conducted advertisement to sell the townhouses. They kept the townhouses for a year so that higher returns could be achieved. These systematic business actions would lead to tax liability on the taxpayers (CCh, 2016e). References Barkoczy,S 2015,Foundation of Taxation Law 2015,7th eds., CCH Publications, North Ryde CCh 2016a, FC of T v Whit fords Beach Pty Ltd (1982) 150 CLR, Available online from https://www.iknow.cch.com.au/document/atagUio549860sl16841994/federal-commissioner-of-taxation-v-whitfords-beach-pty-ltd-high-court-of-australia-17-march-1982 (Accessed on September 18, 2016) CCh 2016b, Statham Anor v FC of T 89 ATC 4070, Available online from https://www.iknow.cch.com.au/document/atagUio544343sl16788832/statham-anor-v-federal-commissioner-of-taxation-federal-court-of-australia-full-court-23-december-1988 (Accessed on September 18, 2016) CCh 2016c, Casimaty v FC of T 97 ATC 5135, Available online from https://www.iknow.cch.com.au/document/atagUio539843sl16716249/casimaty-v-fc-of-t-federal-court-of-australia-10-december-1997 (Accessed on September 18, 2016) CCh 2016d, Crow v FC of T 88 ATC 4620, Available online from https://www.iknow.cch.com.au/document/atagUio545564sl16800674/crow-v-federal-commissioner-of-taxation-federal-court-of-australia-17-august-1988 (Accessed on September 18, 2016) CCh 2016e, McCurry Anor v FC of T 98 ATC 4487, Available online from https://www.iknow.cch.com.au/document/atagUio539084sl16707683/mccurry-anor-v-fc-of-t-federal-court-of-australia-15-may-1998 (Accessed on September 18, 2016) CCH 2014, Australian Master Tax Guide 2014, 52nd eds., Wolters Kluwer, Sydney Coleman, C 2011, Australian Tax Analysis, 4th eds., Thomson Reuters (Professional) Australia, Sydney Deutsch, R, Freizer, M, Fullerton, I, Hanley, P, Snape, T 2016, Australian tax handbook 9th eds., Thomson Reuters, Pymont Gilders, F, Taylor, J, Walpole, M, Burton, M. Ciro, T 2015, Understanding taxation law 2015, 7th eds., LexisNexis/Butterworths Jade 2016, Scottish Australian Mining Co Ltd v FC of T (1950) 81 CLR 188, Available online from https://jade.io/j/?a=outlineid=64663 (Accessed on September 18, 2016) Nethercott, L, Richardson, G Devos, K 2016, Australian Taxation Study Manual 2016, 4th ed., Oxford University Press, Sydney, Sadiq, K, Coleman, C, Hanegbi, R, Jogarajan, S, Krever, R, Obst, W, and Ting, A 2016,Principles of Taxation Law 2016,8th edn, Thomson Reuters, Pymont