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.
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.