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

99 Pages Posted: 21 Sep 2008 Last revised: 12 Oct 2008

See all articles by Henry Ordower

Henry Ordower

Saint Louis University - School of Law

Date Written: 1993

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.

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: https://ssrn.com/abstract=1270630

Henry Ordower (Contact Author)

Saint Louis University - School of Law ( email )

100 N. Tucker Blvd.
St. Louis, MO 63101
United States

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