We examine the tax rules for ownership of fungible securities in light of three recent cases addressing this issue …, Samueli, Calloway, and Anschutz. We argue that ownership has no economic basis under an income tax because under a pure income … tax ownership would not be needed to measure income. Rather than acting as a bedrock principle based in economics …

Although first possession is generally assumed to be the dominant means of establishing original ownership of property …, there is a second but less studied principle for initiating ownership, called accession, which awards new resources to the …, from determining rights to baby animals and growing crops to determining ownership of derivative rights under intellectual …