Tax Law Commons^™

A Comprehensive Attack On Tax Deferral, Mary Louise Fellows

Michigan Law Review

This article explores the operation of T ARET and demonstrates that it produces economic neutrality and fairness among taxpayers, while simplifying the tax system by eliminating the need for provisions designed to reduce deferral advantages or ameliorate the inequities created by the realization-event rule. Finally, even if one decides that TARET should not be implemented, considering its operation provides a useful and quite different perspective on tax policy and taxing issues. In Simons' words, exploring the T ARET model allows us "to consider fruitfully the problem of bettering the system of presumptions."

Part I establishes the foundation for the time-adjustment …