Document Type
Article
Publication Date
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.
Recommended 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.