Revisiting Realization: Accretion Taxation, the Constitution, Macomber, and Mark to Market

Ordower, Henry

Abstract

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Revisiting Realization: Accretion Taxation, the Constitution, Macomber, and Mark to Market

Henry Ordower

Saint Louis University - School of Law

1993

Virginia Tax Review, Vol. 13, No. 1, pp. 1-99, Summer 1993
Saint Louis U. Legal Studies Research Paper

Abstract:
Reviews the constitutional origin of the United States realization based income taxation system and concludes that modification of that system to an accrual or accretion system would be constitutionally infirm. The article examines certain accretion rules currently in the United States tax laws, identifies the flaws in the reasoning in support of those rules in the legislative history and seeks to explain why the industries affected generally have not complained about the rules.

Number of Pages in PDF File: 99

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Date posted: September 21, 2008 ; Last revised: October 12, 2008

Suggested Citation

Ordower, Henry, Revisiting Realization: Accretion Taxation, the Constitution, Macomber, and Mark to Market (1993). Virginia Tax Review, Vol. 13, No. 1, pp. 1-99, Summer 1993; Saint Louis U. Legal Studies Research Paper. Available at SSRN: http://ssrn.com/abstract=1270630

Contact Information

Henry Ordower (Contact Author)

Saint Louis University - School of Law ( email )

3700 Lindell Blvd
St. Louis, MO 63108
United States