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A persistent problem in the theory of income taxation is whether natural
persons should be taxed as isolated individuals, or as social beings whose
family ties to other taxpayers affect their taxpaying capacity. From its inception, the federal income tax law has permitted every taxpayer to file a
personal return, embracing his or her own income but excluding the income
of the taxpayer's spouse, children, and other relatives. On the other
hand, married couples may elect to consolidate their income on a joint
return, many exemptions and deductions take account of family links and
responsibilities, and the income or property of one member of a family is
sometimes attributed to another member for a variety of tax purposes. The
Internal Revenue Code, in brief, is a patchwork, its history being a myriad
of compromises fashioned to meet particular problems.

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