Brief of Amici Curiae in Support of Respondent in Moore v. United States, Docket 22-800

39 Pages Posted: 17 Nov 2023

See all articles by Bret Wells

Bret Wells

University of Houston Law Center

Reuven S. Avi-Yonah

University of Michigan Law School

Clint Wallace

University of South Carolina School of Law

Date Written: October 20, 2023

Abstract

The brief authors assert that a victory for the Moores would call into question the constitutionality of at least a dozen longstanding provisions of the Internal Revenue Code and creates the specter that only some income derived from property owners will be subject to tax while those who derive their income from wages will invariably continue to pay.

Keywords: Realization, Nonrealization, Macomber, 16th Amendment, Sixteenth Amendment

Suggested Citation

Wells, Bret and Avi-Yonah, Reuven S. and Wallace, Clint, Brief of Amici Curiae in Support of Respondent in Moore v. United States, Docket 22-800 (October 20, 2023). Available at SSRN: https://ssrn.com/abstract=4607547 or http://dx.doi.org/10.2139/ssrn.4607547

Bret Wells (Contact Author)

University of Houston Law Center ( email )

4604 Calhoun Road
4604 Calhoun Road
Houston, TX 77204-6060
United States

Reuven S. Avi-Yonah

University of Michigan Law School ( email )

625 South State Street
Ann Arbor, MI 48109-1215
United States
734-647-4033 (Phone)

Clint Wallace

University of South Carolina School of Law ( email )

1525 Senate Street
Columbia, SC 29208
United States

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