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The Tax Trench Deepens, Tracey M. Roberts Oct 2025

The Tax Trench Deepens, Tracey M. Roberts

Florida Tax Review

Congress, long divided, has been in gridlock for decades. The result has been regulatory ossification. Existing statutes lack the flexibility to manage the country’s many technological, social, environmental, sectoral and market challenges. However, without a Senate supermajority vote to override the filibuster, new legislation fails. While the budget reconciliation process has provided one of the few pathways around the filibuster, that process is limited to budgetary outlays and revenue measures. Consequently, a “tax trench” has been worn from Congress repeatedly pushing major regulatory and public benefits legislation through the process as tax provisions. Now, the tax trench is set to …


Have Your Cake And Eat It Too, Using Apportionment To Preserve Congress's Tax Power, Donald B. Tobin Oct 2025

Have Your Cake And Eat It Too, Using Apportionment To Preserve Congress's Tax Power, Donald B. Tobin

Florida Tax Review

The Constitution provides Congress with extremely broad taxing power, and the Supreme Court has recognized that this power is “virtually without limitation.” As budget deficits and income inequality in the United States increase, policymakers are examining options to tax wealth, either through a wealth tax or through taxes on untaxed capital gains. Opponents of these measures have turned to the apportionment requirement in the Constitution and argued that these taxes are not “income taxes” and instead are “direct taxes” that must be apportioned among the states. They further argue that since these taxes cannot be apportioned fairly, any wealth tax …


Moore Questions, Some Answers: Fixing The Personal Tax System Despite Constitutional Constraints, David Gamage, John R. Brooks, Edward J. Mccaffery Oct 2025

Moore Questions, Some Answers: Fixing The Personal Tax System Despite Constitutional Constraints, David Gamage, John R. Brooks, Edward J. Mccaffery

Florida Tax Review

Moore v. United States was expected to rule on the constitutional necessity of the tax-law realization requirement originating from Eisner v. Macomber, a potential impediment to progressive tax reform efforts aimed at shutting down the planning techniques of Buy Borrow Die. The various opinions in Moore, however, provided no definitive answer to this core question, instead leaving many more questions. Amid the lingering uncertainty, we argue that various responses to the problem of wealthy Americans’ not needing to pay any taxes remain possible after Moore. An incremental, “mix-and-match” approach to progressive tax reform may best suit …


Containing The Blast Radius: Can Congress Save The Code From Realization?, Reuven Avi-Yonah, Elise Hocking, Muskan Sharma Oct 2025

Containing The Blast Radius: Can Congress Save The Code From Realization?, Reuven Avi-Yonah, Elise Hocking, Muskan Sharma

Florida Tax Review

The Supreme Court’s decision in Moore v. United States avoided enshrining realization as a constitutional requirement for taxing income. But four Justices were in favor of doing so, and the majority opinion explicitly avoided deciding the issue. Thus, it is quite plausible to imagine that a future case would garner five votes in favor of constitutionalizing realization. This Article addresses the question whether Congress can do anything preemptively to contain the “blast radius” of such an explosive decision and limit the ensuing “fiscal calamity.”


Charles And Kathleen Moore And The Coming Tax Armageddon, Calvin H. Johnson Oct 2025

Charles And Kathleen Moore And The Coming Tax Armageddon, Calvin H. Johnson

Florida Tax Review

The Supreme Court decided last term, against predictions, that U.S. shareholders could be taxed on the undistributed earnings of their foreign corporation. The Court expressly did not decide the “Armageddon question,” whether a wealth tax or mark-to-market tax would be constitutional.

In the coming Armageddon, the Court needs to reverse the error in Pollock v. Farmers’ Loan & Trust Co., which said that the Constitution “prevent[s] an attack upon accumulated property by mere force of numbers.” That is exactly wrong. Apportionment of direct tax in fact was written to reach the wealth of the states using the labor of …


Identifying And Examining Access And Barriers To Healthcare For The Transgender And Nonbinary Individual, Allison Gould Oct 2025

Identifying And Examining Access And Barriers To Healthcare For The Transgender And Nonbinary Individual, Allison Gould

Doctor of Education Program Dissertations

The purpose of this qualitative phenomenological study was to explore the lived experiences of transgender and nonbinary (TNB) individuals related to their access to basic healthcare. Currently, the TNB population is experiencing disparities in accessing general and preventative healthcare in comparison to their cisgendered counterparts. I developed the research questions to explore how TNB individuals describe their access to general and preventative healthcare, identify what were perceived as barriers in seeking basic healthcare, and describe what was subjectively identified as a positive healthcare experiences. My personal and professional interest as a physical therapist combined with a thorough literature review, and …


The Effect Of A 50-Mile Ultra-Marathon Race On Arterial Stiffness, N Bearup, V Cave, Z Climenhaga, M Baxter, K Dames, J Parks Oct 2025

The Effect Of A 50-Mile Ultra-Marathon Race On Arterial Stiffness, N Bearup, V Cave, Z Climenhaga, M Baxter, K Dames, J Parks

International Journal of Exercise Science: Conference Proceedings

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The Acute Effects Of Action Observation Perspective On Lower Limb Strength, E Beinstein, F Saechao, Z Pourhatami, R Dimaio, K Harmon Oct 2025

The Acute Effects Of Action Observation Perspective On Lower Limb Strength, E Beinstein, F Saechao, Z Pourhatami, R Dimaio, K Harmon

International Journal of Exercise Science: Conference Proceedings

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Sickle Cell Disease Increases Glycolytic Muscle Fiber Proportions While Impairing Muscular Strength In Mice, E Bota, M Da Silva, C Hart, D Kim, S Kuzmiak-Glancy, S Prior Oct 2025

Sickle Cell Disease Increases Glycolytic Muscle Fiber Proportions While Impairing Muscular Strength In Mice, E Bota, M Da Silva, C Hart, D Kim, S Kuzmiak-Glancy, S Prior

International Journal of Exercise Science: Conference Proceedings

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No Effects Of Acute Refueling Composition On Soccer Athlete Motivation Measures During Pre-Season Training, N Bruan, D Ebert, D Williams, J Nelligan, W Braun Facsm Oct 2025

No Effects Of Acute Refueling Composition On Soccer Athlete Motivation Measures During Pre-Season Training, N Bruan, D Ebert, D Williams, J Nelligan, W Braun Facsm

International Journal of Exercise Science: Conference Proceedings

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Comparing Virtual Reality Derived-Bess Scores And Human Evaluation Scores, A Breneman, L Custer Oct 2025

Comparing Virtual Reality Derived-Bess Scores And Human Evaluation Scores, A Breneman, L Custer

International Journal of Exercise Science: Conference Proceedings

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Arterial Stiffness, Theta Oscillations In Resting State Eeg, And Neurovascular Coupling In Young Adults, S Brice, A Rios, S Downing, T Shadat, K Kuwahara, S Troller-Renfree, K Heffernan Oct 2025

Arterial Stiffness, Theta Oscillations In Resting State Eeg, And Neurovascular Coupling In Young Adults, S Brice, A Rios, S Downing, T Shadat, K Kuwahara, S Troller-Renfree, K Heffernan

International Journal of Exercise Science: Conference Proceedings

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Upf Consumption And Type 2 Diabetes Risk In Middle-Aged Adults On A Controlled Diet, B Capra, S Hudson, K Phillips, E Marinik, E Laskaridou, A Johnson, E Wilson, M Dong, L David, J Salva, V Hedrick, K Davy Facsm, B Davy Facsm Oct 2025

Upf Consumption And Type 2 Diabetes Risk In Middle-Aged Adults On A Controlled Diet, B Capra, S Hudson, K Phillips, E Marinik, E Laskaridou, A Johnson, E Wilson, M Dong, L David, J Salva, V Hedrick, K Davy Facsm, B Davy Facsm

International Journal of Exercise Science: Conference Proceedings

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Large Artery Stiffness And Neurovascular Coupling Across The Lifespan: Impact Of Age And Sex, J Cassette, S Brice, A Rios, K Kuwahara, W Lefferts, K Heffernan Oct 2025

Large Artery Stiffness And Neurovascular Coupling Across The Lifespan: Impact Of Age And Sex, J Cassette, S Brice, A Rios, K Kuwahara, W Lefferts, K Heffernan

International Journal of Exercise Science: Conference Proceedings

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The Effect Of A 50-Mile Ultra-Marathon Race On Autonomic Modulation, V Cave, N Bearup, M Baxter, Z Climenhaga, K Dames, J Parks Oct 2025

The Effect Of A 50-Mile Ultra-Marathon Race On Autonomic Modulation, V Cave, N Bearup, M Baxter, Z Climenhaga, K Dames, J Parks

International Journal of Exercise Science: Conference Proceedings

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Impact Of Core Strengthening On Walking Endurance And Fall Risk Perception In Adults Over 65, M Cencetti, N Evanosky, V Fama, B Kelley, C Mcnamara, M Nicholson, J Tanis Oct 2025

Impact Of Core Strengthening On Walking Endurance And Fall Risk Perception In Adults Over 65, M Cencetti, N Evanosky, V Fama, B Kelley, C Mcnamara, M Nicholson, J Tanis

International Journal of Exercise Science: Conference Proceedings

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Impact Of Seasonal Exercise Training On Cardiometabolic Risk In Adults With Obesity, I Chee, E Heiston, S Malin Facsm Oct 2025

Impact Of Seasonal Exercise Training On Cardiometabolic Risk In Adults With Obesity, I Chee, E Heiston, S Malin Facsm

International Journal of Exercise Science: Conference Proceedings

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Changes In Muscle Size, Strength, And Exercise Adherence Following A Peer-Leader Program, J Chernyenko, L Gordy, J Schott, V Tymoshenko, S Leusner, Z Furey, S Dankel Oct 2025

Changes In Muscle Size, Strength, And Exercise Adherence Following A Peer-Leader Program, J Chernyenko, L Gordy, J Schott, V Tymoshenko, S Leusner, Z Furey, S Dankel

International Journal of Exercise Science: Conference Proceedings

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Cohesion, Motivation, And Stress Resilience Effects On Collegiate Football Performance And Well-Being, T Chhabra, K Jaquess Oct 2025

Cohesion, Motivation, And Stress Resilience Effects On Collegiate Football Performance And Well-Being, T Chhabra, K Jaquess

International Journal of Exercise Science: Conference Proceedings

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Beverage Versus Capsule Delivery Of Inorganic Nitrate: Effects On Exercise Economy In Postmenopausal Females, K Clark, M Stahl, E Grammer, J Allen, A Weltman Oct 2025

Beverage Versus Capsule Delivery Of Inorganic Nitrate: Effects On Exercise Economy In Postmenopausal Females, K Clark, M Stahl, E Grammer, J Allen, A Weltman

International Journal of Exercise Science: Conference Proceedings

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Recovery Of Heart Rate Complexity After A 50-Mile Ultra-Marathon Race, Z Climenhaga, M Baxter, V Cave, N Bearup, K Dames, J Parks Oct 2025

Recovery Of Heart Rate Complexity After A 50-Mile Ultra-Marathon Race, Z Climenhaga, M Baxter, V Cave, N Bearup, K Dames, J Parks

International Journal of Exercise Science: Conference Proceedings

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The Effects Of Senaptec Vision Training On Hitting Stats In Ncaa Division Ii Baseball Players, A Colecio, B Finn, B Snyder, S Davis Facsm, C Saker, T Jordan Oct 2025

The Effects Of Senaptec Vision Training On Hitting Stats In Ncaa Division Ii Baseball Players, A Colecio, B Finn, B Snyder, S Davis Facsm, C Saker, T Jordan

International Journal of Exercise Science: Conference Proceedings

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Effect Of Anatomical Placement On Accuracy Of Wearable Heart Rate Monitors Across Activity Intensities, J Collins, C Gardner, M Moghaddam, M Rabel Oct 2025

Effect Of Anatomical Placement On Accuracy Of Wearable Heart Rate Monitors Across Activity Intensities, J Collins, C Gardner, M Moghaddam, M Rabel

International Journal of Exercise Science: Conference Proceedings

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Comparison Of Visceral Fat Area Using Bioelectrical Impedance To Dual-Energy X-Ray Absorptiometry, T Combest, T Sergi, D Yadavongsy-Clinton, N Watson Oct 2025

Comparison Of Visceral Fat Area Using Bioelectrical Impedance To Dual-Energy X-Ray Absorptiometry, T Combest, T Sergi, D Yadavongsy-Clinton, N Watson

International Journal of Exercise Science: Conference Proceedings

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Pre-Exercise And Recovery Peripheral And Central Hemodynamic Response Unchanged Following Three Weekly Maximal Exercise Tests, K Combs, M Danser, M Lozada, J Benton, J Keeler, C Carriker Oct 2025

Pre-Exercise And Recovery Peripheral And Central Hemodynamic Response Unchanged Following Three Weekly Maximal Exercise Tests, K Combs, M Danser, M Lozada, J Benton, J Keeler, C Carriker

International Journal of Exercise Science: Conference Proceedings

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Effects Of A Multicomponent Training Program On Health Outcomes In Community-Dwelling Older Adults, T Craig, S Davis Facsm, S Munford, M Cencetti, B Goodrich Oct 2025

Effects Of A Multicomponent Training Program On Health Outcomes In Community-Dwelling Older Adults, T Craig, S Davis Facsm, S Munford, M Cencetti, B Goodrich

International Journal of Exercise Science: Conference Proceedings

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Post-Exercise Vagal Recovery During Cognitive Testing, P Cutrufello Iii, T Guidetti, M Robb, R Cannataro, M Landram, A Venezia Oct 2025

Post-Exercise Vagal Recovery During Cognitive Testing, P Cutrufello Iii, T Guidetti, M Robb, R Cannataro, M Landram, A Venezia

International Journal of Exercise Science: Conference Proceedings

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A Comparison Of Three Metabolic Carts During Graded Exercise Testing, M Danser, K Combs, M Lozada, J Benton, J Keeler, C Carriker Oct 2025

A Comparison Of Three Metabolic Carts During Graded Exercise Testing, M Danser, K Combs, M Lozada, J Benton, J Keeler, C Carriker

International Journal of Exercise Science: Conference Proceedings

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Metabolic And Physiological Effects Of Allulose On Half-Marathon Performance In Trained Male Runners, C Decarlo, P Prins, J Buxton, A Beyer, A Haynes, N Soltz, R Johnson, A Koutnik Oct 2025

Metabolic And Physiological Effects Of Allulose On Half-Marathon Performance In Trained Male Runners, C Decarlo, P Prins, J Buxton, A Beyer, A Haynes, N Soltz, R Johnson, A Koutnik

International Journal of Exercise Science: Conference Proceedings

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The Effects Of Added Sugar Intake On Sleep Health In Midlife Adults, K Decker, Z Rigas, C Awad, N Rizzi, M D'Agata, M Witman, S Lennon, C Martens Oct 2025

The Effects Of Added Sugar Intake On Sleep Health In Midlife Adults, K Decker, Z Rigas, C Awad, N Rizzi, M D'Agata, M Witman, S Lennon, C Martens

International Journal of Exercise Science: Conference Proceedings

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