id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
taxlaw-12712	Speck, Sloan G.	The Realization Rule as a Legal Standard	2024	50	.pdf	application/pdf	28260	1285	46	150 See Moore, 144 S. Ct. at 1707 (Barrett, J., concurring) (arguing that Congress’s ability to attribute an entity’s income to shareholders “depends on the relationship between the shareholder and the income.”). 2024] REALIZATION RULE AS A LEGAL STANDARD 21 Similarly, Barrett’s construction of constitutional realization emphasizes the inquiry’s broad, contextual nature. Taken together, the Barrett and Thomas opinions strongly support a constitutional realization requirement, while the Kavanaugh majority avoids taking a position on the issue.136 Only Justice Jackson’s concurrence takes a clear position against constitutional realization, and the absence of other Justices joining her opinion emphasizes the Court’s instability on the issue.	cache/taxlaw-12712.pdf	txt/taxlaw-12712.txt