The Haig-Simons concept of income has for roughly fifty years been a gold standard of income tax theory and policy discussion. This article argues that the classic Haig-Simons formulation of personal income, which consists of an individual's consumption plus net increases in wealth for the...

The idea advanced herein, as a thought experiment, is the possibility of expanding (by legislation) – or possibly interpreting (by Treasury regulation) – section 265(a)(1) to disallow deductions deemed to have paid out of tax-exempt (i.e., excluded) income. Although section 265(a)(1) already...