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By americans. It w brought forward by a plaintiff who objected to a clause in a 2017 change in tax law that would have wired a repatriation tax. This is about two. The court squarely held us much just a few years foowg adoption of the amendment. The the presidt kes easy work of the case. It is undisputed the petiors realize nothing from their stock investment. They were taxed not because they had income but becse in 2017 they happened to own sharein corporation. This is a taxn e ownership of property. Dispensing with the need for realization, the framers regarded this as the essential chec on the power of congress to taxrorty. The government cannot identify a single thing congress could not tax its income under its position realization is unnecessary. Without realization there is no limiting principle. Accepting th government position on income would make a cap hash of the current law. Gateway defition of gross income asserts congresses taxing por der the 16th amendment roh reaching al

Power congressCongress taxIncome taxCorporation capitalValue capitalState lawLaw partnershipCorporation personShareholders corporationPartnerships groupGroup peopleCorporate structureBasis corporationCompany companyCompany ownedControlling shareholder