Il giudice tributario come giudice europeo

Questo lavoro, tramite un'analisi attenta ed accurata dello sviluppo delle pronunce della Corte di Giustizia in materia tributaria, ha lo scopo di mettere in evidenza i canoni interpretativi utilizzati dalla Corte, tenendo presente gli effetti che tali pronunce hanno prodotto nei singoli stati ed in particolare sul ruolo del giudice tributario come giudice europeo. Assistiamo infatti oggi ad una vera e propria europeizzazione della produzione giuridica in grado di aprire nuovi spiragli alla tutela del cittadino anche nei confronti dell'amministrazione finanziaria. L'interazione, per molti aspetti problematica, tra gli organi di giustizia tributaria dei singoli ordinamenti ed il giudice comunitario sono diventate vera e propria fucina di un diritto tributario europeo, nell'ambito del quale a svolgere un ruolo di estrema rilevanza è il giudice interno. Le sentenze del giudice tributario nazionale infatti rappresentano lo strumento più efficace di chiarificazione del diritto comunitario. Il presente lavoro si propone quindi di esaminare nel dettaglio il rapporto complementare e funzionalista che si estrinseca nella peculiare funzione attribuita al giudice tributario nazionale che gli fa assumere le vesti di "giudice europeo" nonché la funzione attribuita alla Corte di Giustizia che assume i caratteri sempre più marcati di "giudice tributario sovranazionale". Partendo dalla disamina delle figure dei giudici tributari di Germania, Francia ed Italia, si passerà poi ad evidenziare i ruoli che hanno avuto le Corti nazionali nell'applicazione del diritto comunitario, evidenziando come nei vari casi le sentenze si sono affiancate alla preminenza gerarchica della norma europea.

The VIMOS-VLT Deep Survey: the evolution of type-1 AGN

Quasars and AGN play an important role in many aspects of the modern cosmology. Of particular interest is the issue of the interplay between AGN activity and formation and evolution of galaxies and structures. Studies on nearby galaxies revealed that most (and possibly all) galaxy nuclei contain a super-massive black hole (SMBH) and that between a third and half of them are showing some evidence of activity (Kormendy and Richstone, 1995). The discovery of a tight relation between black holes mass and velocity dispersion of their host galaxy suggests that the evolution of the growth of SMBH and their host galaxy are linked together. In this context, studying the evolution of AGN, through the luminosity function (LF), is fundamental to constrain the theories of galaxy and SMBH formation and evolution. Recently, many theories have been developed to describe physical processes possibly responsible of a common formation scenario for galaxies and their central black hole (Volonteri et al., 2003; Springel et al., 2005a; Vittorini et al., 2005; Hopkins et al., 2006a) and an increasing number of observations in different bands are focused on collecting larger and larger quasar samples. Many issues remain however not yet fully understood. In the context of the VVDS (VIMOS-VLT Deep Survey), we collected and studied an unbiased sample of spectroscopically selected faint type-1 AGN with a unique and straightforward selection function. Indeed, the VVDS is a large, purely magnitude limited spectroscopic survey of faint objects, free of any morphological and/or color preselection. We studied the statistical properties of this sample and its evolution up to redshift z 4. Because of the contamination of the AGN light by their host galaxies at the faint magnitudes explored by our sample, we observed that a significant fraction of AGN in our sample would be missed by the UV excess and morphological criteria usually adopted for the pre-selection of optical QSO candidates. If not properly taken into account, this failure in selecting particular sub-classes of AGN could, in principle, affect some of the conclusions drawn from samples of AGN based on these selection criteria. The absence of any pre-selection in the VVDS leads us to have a very complete sample of AGN, including also objects with unusual colors and continuum shape. The VVDS AGN sample shows in fact redder colors than those expected by comparing it, for example, with the color track derived from the SDSS composite spectrum. In particular, the faintest objects have on average redder colors than the brightest ones. This can be attributed to both a large fraction of dust-reddened objects and a significant contamination from the host galaxy. We have tested these possibilities by examining the global spectral energy distribution of each object using, in addition to the U, B, V, R and I-band magnitudes, also the UV-Galex and the IR-Spitzer bands, and fitting it with a combination of AGN and galaxy emission, allowing also for the possibility of extinction of the AGN flux. We found that for 44% of our objects the contamination from the host galaxy is not negligible and this fraction decreases to 21% if we restrict the analysis to a bright subsample (M1450 <-22.15). Our estimated integral surface density at IAB < 24.0 is 500 AGN per square degree, which represents the highest surface density of a spectroscopically confirmed sample of optically selected AGN. We derived the luminosity function in B-band for 1.0 < z < 3.6 using the 1/Vmax estimator. Our data, more than one magnitude fainter than previous optical surveys, allow us to constrain the faint part of the luminosity function up to high redshift. A comparison of our data with the 2dF sample at low redshift (1 < z < 2.1) shows that the VDDS data can not be well fitted with the pure luminosity evolution (PLE) models derived by previous optically selected samples. Qualitatively, this appears to be due to the fact that our data suggest the presence of an excess of faint objects at low redshift (1.0 < z < 1.5) with respect to these models. By combining our faint VVDS sample with the large sample of bright AGN extracted from the SDSS DR3 (Richards et al., 2006b) and testing a number of different evolutionary models, we find that the model which better represents the combined luminosity functions, over a wide range of redshift and luminosity, is a luminosity dependent density evolution (LDDE) model, similar to those derived from the major Xsurveys. Such a parameterization allows the redshift of the AGN density peak to change as a function of luminosity, thus fitting the excess of faint AGN that we find at 1.0 < z < 1.5. On the basis of this model we find, for the first time from the analysis of optically selected samples, that the peak of the AGN space density shifts significantly towards lower redshift going to lower luminosity objects. The position of this peak moves from z 2.0 for MB <-26.0 to z 0.65 for -22< MB <-20. This result, already found in a number of X-ray selected samples of AGN, is consistent with a scenario of “AGN cosmic downsizing”, in which the density of more luminous AGN, possibly associated to more massive black holes, peaks earlier in the history of the Universe (i.e. at higher redshift), than that of low luminosity ones, which reaches its maximum later (i.e. at lower redshift). This behavior has since long been claimed to be present in elliptical galaxies and it is not easy to reproduce it in the hierarchical cosmogonic scenario, where more massive Dark Matter Halos (DMH) form on average later by merging of less massive halos.

Statistical properties of Radio Halos and the re-acceleration model

Galaxy clusters occupy a special position in the cosmic hierarchy as they are the largest bound structures in the Universe. There is now general agreement on a hierarchical picture for the formation of cosmic structures, in which galaxy clusters are supposed to form by accretion of matter and merging between smaller units. During merger events, shocks are driven by the gravity of the dark matter in the diffuse barionic component, which is heated up to the observed temperature. Radio and hard-X ray observations have discovered non-thermal components mixed with the thermal Intra Cluster Medium (ICM) and this is of great importance as it calls for a “revision” of the physics of the ICM. The bulk of present information comes from the radio observations which discovered an increasing number of Mpcsized emissions from the ICM, Radio Halos (at the cluster center) and Radio Relics (at the cluster periphery). These sources are due to synchrotron emission from ultra relativistic electrons diffusing through µG turbulent magnetic fields. Radio Halos are the most spectacular evidence of non-thermal components in the ICM and understanding the origin and evolution of these sources represents one of the most challenging goal of the theory of the ICM. Cluster mergers are the most energetic events in the Universe and a fraction of the energy dissipated during these mergers could be channelled into the amplification of the magnetic fields and into the acceleration of high energy particles via shocks and turbulence driven by these mergers. Present observations of Radio Halos (and possibly of hard X-rays) can be best interpreted in terms of the reacceleration scenario in which MHD turbulence injected during these cluster mergers re-accelerates high energy particles in the ICM. The physics involved in this scenario is very complex and model details are difficult to test, however this model clearly predicts some simple properties of Radio Halos (and resulting IC emission in the hard X-ray band) which are almost independent of the details of the adopted physics. In particular in the re-acceleration scenario MHD turbulence is injected and dissipated during cluster mergers and thus Radio Halos (and also the resulting hard X-ray IC emission) should be transient phenomena (with a typical lifetime <» 1 Gyr) associated with dynamically disturbed clusters. The physics of the re-acceleration scenario should produce an unavoidable cut-off in the spectrum of the re-accelerated electrons, which is due to the balance between turbulent acceleration and radiative losses. The energy at which this cut-off occurs, and thus the maximum frequency at which synchrotron radiation is produced, depends essentially on the efficiency of the acceleration mechanism so that observations at high frequencies are expected to catch only the most efficient phenomena while, in principle, low frequency radio surveys may found these phenomena much common in the Universe. These basic properties should leave an important imprint in the statistical properties of Radio Halos (and of non-thermal phenomena in general) which, however, have not been addressed yet by present modellings. The main focus of this PhD thesis is to calculate, for the first time, the expected statistics of Radio Halos in the context of the re-acceleration scenario. In particular, we shall address the following main questions: • Is it possible to model “self-consistently” the evolution of these sources together with that of the parent clusters? • How the occurrence of Radio Halos is expected to change with cluster mass and to evolve with redshift? How the efficiency to catch Radio Halos in galaxy clusters changes with the observing radio frequency? • How many Radio Halos are expected to form in the Universe? At which redshift is expected the bulk of these sources? • Is it possible to reproduce in the re-acceleration scenario the observed occurrence and number of Radio Halos in the Universe and the observed correlations between thermal and non-thermal properties of galaxy clusters? • Is it possible to constrain the magnetic field intensity and profile in galaxy clusters and the energetic of turbulence in the ICM from the comparison between model expectations and observations? Several astrophysical ingredients are necessary to model the evolution and statistical properties of Radio Halos in the context of re-acceleration model and to address the points given above. For these reason we deserve some space in this PhD thesis to review the important aspects of the physics of the ICM which are of interest to catch our goals. In Chapt. 1 we discuss the physics of galaxy clusters, and in particular, the clusters formation process; in Chapt. 2 we review the main observational properties of non-thermal components in the ICM; and in Chapt. 3 we focus on the physics of magnetic field and of particle acceleration in galaxy clusters. As a relevant application, the theory of Alfv´enic particle acceleration is applied in Chapt. 4 where we report the most important results from calculations we have done in the framework of the re-acceleration scenario. In this Chapter we show that a fraction of the energy of fluid turbulence driven in the ICM by the cluster mergers can be channelled into the injection of Alfv´en waves at small scales and that these waves can efficiently re-accelerate particles and trigger Radio Halos and hard X-ray emission. The main part of this PhD work, the calculation of the statistical properties of Radio Halos and non-thermal phenomena as expected in the context of the re-acceleration model and their comparison with observations, is presented in Chapts.5, 6, 7 and 8. In Chapt.5 we present a first approach to semi-analytical calculations of statistical properties of giant Radio Halos. The main goal of this Chapter is to model cluster formation, the injection of turbulence in the ICM and the resulting particle acceleration process. We adopt the semi–analytic extended Press & Schechter (PS) theory to follow the formation of a large synthetic population of galaxy clusters and assume that during a merger a fraction of the PdV work done by the infalling subclusters in passing through the most massive one is injected in the form of magnetosonic waves. Then the processes of stochastic acceleration of the relativistic electrons by these waves and the properties of the ensuing synchrotron (Radio Halos) and inverse Compton (IC, hard X-ray) emission of merging clusters are computed under the assumption of a constant rms average magnetic field strength in emitting volume. The main finding of these calculations is that giant Radio Halos are naturally expected only in the more massive clusters, and that the expected fraction of clusters with Radio Halos is consistent with the observed one. In Chapt. 6 we extend the previous calculations by including a scaling of the magnetic field strength with cluster mass. The inclusion of this scaling allows us to derive the expected correlations between the synchrotron radio power of Radio Halos and the X-ray properties (T, LX) and mass of the hosting clusters. For the first time, we show that these correlations, calculated in the context of the re-acceleration model, are consistent with the observed ones for typical µG strengths of the average B intensity in massive clusters. The calculations presented in this Chapter allow us to derive the evolution of the probability to form Radio Halos as a function of the cluster mass and redshift. The most relevant finding presented in this Chapter is that the luminosity functions of giant Radio Halos at 1.4 GHz are expected to peak around a radio power » 1024 W/Hz and to flatten (or cut-off) at lower radio powers because of the decrease of the electron re-acceleration efficiency in smaller galaxy clusters. In Chapt. 6 we also derive the expected number counts of Radio Halos and compare them with available observations: we claim that » 100 Radio Halos in the Universe can be observed at 1.4 GHz with deep surveys, while more than 1000 Radio Halos are expected to be discovered in the next future by LOFAR at 150 MHz. This is the first (and so far unique) model expectation for the number counts of Radio Halos at lower frequency and allows to design future radio surveys. Based on the results of Chapt. 6, in Chapt.7 we present a work in progress on a “revision” of the occurrence of Radio Halos. We combine past results from the NVSS radio survey (z » 0.05 − 0.2) with our ongoing GMRT Radio Halos Pointed Observations of 50 X-ray luminous galaxy clusters (at z » 0.2−0.4) and discuss the possibility to test our model expectations with the number counts of Radio Halos at z » 0.05 − 0.4. The most relevant limitation in the calculations presented in Chapt. 5 and 6 is the assumption of an “averaged” size of Radio Halos independently of their radio luminosity and of the mass of the parent clusters. This assumption cannot be released in the context of the PS formalism used to describe the formation process of clusters, while a more detailed analysis of the physics of cluster mergers and of the injection process of turbulence in the ICM would require an approach based on numerical (possible MHD) simulations of a very large volume of the Universe which is however well beyond the aim of this PhD thesis. On the other hand, in Chapt.8 we report our discovery of novel correlations between the size (RH) of Radio Halos and their radio power and between RH and the cluster mass within the Radio Halo region, MH. In particular this last “geometrical” MH − RH correlation allows us to “observationally” overcome the limitation of the “average” size of Radio Halos. Thus in this Chapter, by making use of this “geometrical” correlation and of a simplified form of the re-acceleration model based on the results of Chapt. 5 and 6 we are able to discuss expected correlations between the synchrotron power and the thermal cluster quantities relative to the radio emitting region. This is a new powerful tool of investigation and we show that all the observed correlations (PR − RH, PR − MH, PR − T, PR − LX, . . . ) now become well understood in the context of the re-acceleration model. In addition, we find that observationally the size of Radio Halos scales non-linearly with the virial radius of the parent cluster, and this immediately means that the fraction of the cluster volume which is radio emitting increases with cluster mass and thus that the non-thermal component in clusters is not self-similar.

Progetto di reti Sensori Wireless e tecniche di Fusione Sensoriale

Ambient Intelligence (AmI) envisions a world where smart, electronic environments are aware and responsive to their context. People moving into these settings engage many computational devices and systems simultaneously even if they are not aware of their presence. AmI stems from the convergence of three key technologies: ubiquitous computing, ubiquitous communication and natural interfaces. The dependence on a large amount of fixed and mobile sensors embedded into the environment makes of Wireless Sensor Networks one of the most relevant enabling technologies for AmI. WSN are complex systems made up of a number of sensor nodes, simple devices that typically embed a low power computational unit (microcontrollers, FPGAs etc.), a wireless communication unit, one or more sensors and a some form of energy supply (either batteries or energy scavenger modules). Low-cost, low-computational power, low energy consumption and small size are characteristics that must be taken into consideration when designing and dealing with WSNs. In order to handle the large amount of data generated by a WSN several multi sensor data fusion techniques have been developed. The aim of multisensor data fusion is to combine data to achieve better accuracy and inferences than could be achieved by the use of a single sensor alone. In this dissertation we present our results in building several AmI applications suitable for a WSN implementation. The work can be divided into two main areas: Multimodal Surveillance and Activity Recognition. Novel techniques to handle data from a network of low-cost, low-power Pyroelectric InfraRed (PIR) sensors are presented. Such techniques allow the detection of the number of people moving in the environment, their direction of movement and their position. We discuss how a mesh of PIR sensors can be integrated with a video surveillance system to increase its performance in people tracking. Furthermore we embed a PIR sensor within the design of a Wireless Video Sensor Node (WVSN) to extend its lifetime. Activity recognition is a fundamental block in natural interfaces. A challenging objective is to design an activity recognition system that is able to exploit a redundant but unreliable WSN. We present our activity in building a novel activity recognition architecture for such a dynamic system. The architecture has a hierarchical structure where simple nodes performs gesture classification and a high level meta classifiers fuses a changing number of classifier outputs. We demonstrate the benefit of such architecture in terms of increased recognition performance, and fault and noise robustness. Furthermore we show how we can extend network lifetime by performing a performance-power trade-off. Smart objects can enhance user experience within smart environments. We present our work in extending the capabilities of the Smart Micrel Cube (SMCube), a smart object used as tangible interface within a tangible computing framework, through the development of a gesture recognition algorithm suitable for this limited computational power device. Finally the development of activity recognition techniques can greatly benefit from the availability of shared dataset. We report our experience in building a dataset for activity recognition. Such dataset is freely available to the scientific community for research purposes and can be used as a testbench for developing, testing and comparing different activity recognition techniques.

Stellar Relics of the hierarchical assembly of the Galaxy

This PhD Thesis is part of a long-term wide research project, carried out by the "Osservatorio Astronomico di Bologna (INAF-OABO)", that has as primary goal the comprehension and reconstruction of formation mechanism of galaxies and their evolution history. There is now substantial evidence, both from theoretical and observational point of view, in favor of the hypothesis that the halo of our Galaxy has been at least partially, built up by the progressive accretion of small fragments, similar in nature to the present day dwarf galaxies of the Local Group. In this context, the photometric and spectroscopic study of systems which populate the halo of our Galaxy (i.e. dwarf spheroidal galaxy, tidal streams, massive globular cluster, etc) permits to discover, not only the origin and behaviour of these systems, but also the structure of our Galactic halo, combined with its formation history. In fact, the study of the population of these objects and also of their chemical compositions, age, metallicities and velocity dispersion, permit us not only an improvement in the understanding of the mechanisms that govern the Galactic formation, but also a valid indirect test for cosmological model itself. Specifically, in this Thesis we provided a complete characterization of the tidal Stream of the Sagittarius dwarf spheroidal galaxy, that is the most striking example of the process of tidal disruption and accretion of a dwarf satellite in to our Galaxy. Using Red Clump stars, extracted from the catalogue of the Sloan Digital Sky Survey (SDSS) we obtained an estimate of the distance, the depth along the line of sight and of the number density for each detected portion of the Stream (and more in general for each detected structure along our line of sight). Moreover comparing the relative number (i.e. the ratio) of Blue Horizontal Branch stars and Red Clump stars (the two features are tracers of different age/different metallicity populations) in the main body of the galaxy and in the Stream, in order to verify the presence of an age-metallicity gradient along the Stream. We also report the detection of a population of Red Clump stars probably associated with the recently discovered Bootes III stellar system. Finally, we also present the results of a survey of radial velocities over a wide region, extending from r ~ 10' out to r ~ 80' within the massive star cluster Omega Centauri. The survey was performed with FLAMES@VLT, to study the velocity dispersion profile in the outer regions of this stellar system. All the results presented in this Thesis, have already been published in refeered journals.

Welfare provision in Sweden and the dominant position of the Sap

There have been almost fifty years since Harry Eckstein' s classic monograph, A Theory of Stable Democracy (Princeton, 1961), where he sketched out the basic tenets of the “congruence theory”, which was to become one of the most important and innovative contributions to understanding democratic rule. His next work, Division and Cohesion in Democracy, (Princeton University Press: 1966) is designed to serve as a plausibility probe for this 'theory' (ftn.) and is a case study of a Northern democratic system, Norway. What is more, this line of his work best exemplifies the contribution Eckstein brought to the methodology of comparative politics through his seminal article, “ “Case Study and Theory in Political Science” ” (in Greenstein and Polsby, eds., Handbook of Political Science, 1975), on the importance of the case study as an approach to empirical theory. This article demonstrates the special utility of “crucial case studies” in testing theory, thereby undermining the accepted wisdom in comparative research that the larger the number of cases the better. Although not along the same lines, but shifting the case study unit of research, I intend to take up here the challenge and build upon an equally unique political system, the Swedish one. Bearing in mind the peculiarities of the Swedish political system, my unit of analysis is going to be further restricted to the Swedish Social Democratic Party, the Svenska Arbetare Partiet. However, my research stays within the methodological framework of the case study theory inasmuch as it focuses on a single political system and party. The Swedish SAP endurance in government office and its electoral success throughout half a century (ftn. As of the 1991 election, there were about 56 years - more than half century - of interrupted social democratic "reign" in Sweden.) are undeniably a performance no other Social Democrat party has yet achieved in democratic conditions. Therefore, it is legitimate to inquire about the exceptionality of this unique political power combination. Which were the different components of this dominance power position, which made possible for SAP's governmental office stamina? I will argue here that it was the end-product of a combination of multifarious factors such as a key position in the party system, strong party leadership and organization, a carefully designed strategy regarding class politics and welfare policy. My research is divided into three main parts, the historical incursion, the 'welfare' part and the 'environment' part. The first part is a historical account of the main political events and issues, which are relevant for my case study. Chapter 2 is devoted to the historical events unfolding in the 1920-1960 period: the Saltsjoebaden Agreement, the series of workers' strikes in the 1920s and SAP's inception. It exposes SAP's ascent to power in the mid 1930s and the party's ensuing strategies for winning and keeping political office, that is its economic program and key economic goals. The following chapter - chapter 3 - explores the next period, i.e. the period from 1960s to 1990s and covers the party's troubled political times, its peak and the beginnings of the decline. The 1960s are relevant for SAP's planning of a long term economic strategy - the Rehn Meidner model, a new way of macroeconomic steering, based on the Keynesian model, but adapted to the new economic realities of welfare capitalist societies. The second and third parts of this study develop several hypotheses related to SAP's 'dominant position' (endurance in politics and in office) and test them afterwards. Mainly, the twin issues of economics and environment are raised and their political relevance for the party analyzed. On one hand, globalization and its spillover effects over the Swedish welfare system are important causal factors in explaining the transformative social-economic challenges the party had to put up with. On the other hand, Europeanization and environmental change influenced to a great deal SAP's foreign policy choices and its domestic electoral strategies. The implications of globalization on the Swedish welfare system will make the subject of two chapters - chapters four and five, respectively, whereupon the Europeanization consequences will be treated at length in the third part of this work - chapters six and seven, respectively. Apparently, at first sight, the link between foreign policy and electoral strategy is difficult to prove and uncanny, in the least. However, in the SAP's case there is a bulk of literature and public opinion statistical data able to show that governmental domestic policy and party politics are in a tight dependence to foreign policy decisions and sovereignty issues. Again, these country characteristics and peculiar causal relationships are outlined in the first chapters and explained in the second and third parts. The sixth chapter explores the presupposed relationship between Europeanization and environmental policy, on one hand, and SAP's environmental policy formulation and simultaneous agenda-setting at the international level, on the other hand. This chapter describes Swedish leadership in environmental policy formulation on two simultaneous fronts and across two different time spans. The last chapter, chapter eight - while trying to develop a conclusion, explores the alternative theories plausible in explaining the outlined hypotheses and points out the reasons why these theories do not fit as valid alternative explanation to my systemic corporatism thesis as the main causal factor determining SAP's 'dominant position'. Among the alternative theories, I would consider Traedgaardh L. and Bo Rothstein's historical exceptionalism thesis and the public opinion thesis, which alone are not able to explain the half century social democratic endurance in government in the Swedish case.