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By anyone's reckoning, the law concerning the federal income taxation
of corporations and security holders-essentially, subchapter C of
the Internal Revenue Code,' together with its accompanying regulations2
and the accumulated body of revenue rulings and case law3-is
complex. Quite surprisingly for a corpus of rules that is an artificial
construct of highly self-conscious human intellects, rather than an
attempt to rationalize preexisting social relations, the law exhibits an
intricacy approaching that of living systems. The analogy suggests a
question. Did the corporate tax law, like a mature organism, have its
major traits determined by a set of genes fixed in its infancy, or did it
grow in a passive, mechanistic way, its important parts constantly
shaped and reshaped in response to the shifting pressures of a changing

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corporation, tax law