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SFC Casey O'Mally
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Bad ruling IMHO.

16A allows a tax on income. This sort of wealth tax is a tax on POTENTIAL. That unrealized income is NOT YET INCOME.

If the unrealized income turns out to be less, will the Treasury give money back? Not a loss, mind you (which would be deductible) just not as much income as the IRS decided you were GOING to get.

Tax the income when it becomes income. And not before. Anything else violates 16A.

(And yes, I know I lose. SCOTUS decided in a 7-2 majority. But I still say they got it wrong.)
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MAJ Dale E. Wilson, Ph.D.
MAJ Dale E. Wilson, Ph.D.
3 mo
I concur. . . .
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