The article is pure bunk designed to sell papers. When powered down the phone can't be tracked. The OS unloads all of the drivers so it isn't done in software (unless you think the NSA is willing to build OS drivers for all the devices out there) and the radios are powered down. You can't ping a signal off of the device to figure out were it is. First of all GPS decoding is done on device, and as anyone who's ever done Navigation knows, this is a massive power drain. You can't ping the transceivers because the phone has to be in a sleep state in order to respond. Etc, etc, etc.
As for the phone receiving calls, well it's not powered down at that point, just in standby.
If you really need proof that the device can't be tracked turned it off and see how long your battery lasts.
As for the phone receiving calls, well it's not powered down at that point, just in standby.
If you really need proof that the device can't be tracked turned it off and see how long your battery lasts.