FLORIDA TAX REVIEW FLORIDA TAX REVIEW Volume 19 2016 Number 9 ARTICLE THE FAIR TAX: THE PERSONAL REALIZATION INCOME TAX Joseph M. Dodge 522 FLORIDA TAX REVIEW Volume 19 2016 Number 9 The Florida Tax Review is a publication of the Graduate Tax Program of the University of Florida Levin College of Law. The subscription rate, payable in advance, is $125.00 in the United States and $145.00 elsewhere for the current volume. If a subscription is to be discontinued at expiration, notice to that effect should be sent; otherwise, it will be automatically renewed. Subscriptions and changes of address should be sent to: Florida Tax Review, University of Florida Levin College of Law, Post Office Box 117627, Gainesville, Florida 32611. Requests for back issues should be sent to: William S. Hein & Co., Inc., 1285 Main Street, Buffalo, NY 14209. Please notify Florida Tax Review of your changes of address one month in advance. If you have any questions regarding a subscription, you may call Customer Service at (352) 273-0658 or email FTR@law.ufl.edu. Copyright © 2016 by the University of Florida FLORIDA TAX REVIEW Volume 19 2016 Number 9 EDITOR-IN-CHIEF Charlene Luke Professor of Law University of Florida ASSOCIATE EDITORS University of Florida Yariv Brauner Professor of Law Karen Burke Richard B. Stephens Eminent Scholar in Taxation Dennis A. Calfee Professor of Law Patricia E. Dilley Professor Emeritus Michael K. Friel Professor Emeritus David M. Hudson Professor Emeritus Lawrence A. Lokken Emeritus Hugh Culverhouse Eminent Scholar Grayson McCouch Gerald Sohn Professor of Law Adam Smith Visiting Assistant Professor Lee-ford Tritt Professor of Law Samuel C. Ullman Adjunct Professor of Law Steven J. Willis Professor of Law Martin J. McMahon, Jr. James J. Freeland Eminent Scholar BOARD OF ADVISORS Jennifer Bird-Pollan University of Kentucky Bradley T. Borden Brooklyn Law School Deborah A. Geier Cleveland State University Leandra Lederman Indiana University – Bloomington Omri Marion University of California, Irvine Gregg D. Polsky University of Georgia James R. Repetti Boston College Kerry A. Ryan St. Louis University Reed Shuldiner University of Pennsylvania GRADUATE EDITORS Emily Snider Carvalho Brandon C. Gardner Devon Goldberg Jessica E. Griffin William Carroll McDonald Philip Nodhturft, III Benjamin M. Parnell Katheleen Duggan Pfahlert FLORIDA TAX REVIEW Volume 19 2016 Number 9 INFORMATION FOR CONTRIBUTORS The Florida Tax Review invites the submission of manuscripts addressing issues of tax law and policy. The Review publishes several types of manuscripts: “Articles,” “Commentaries,” and “Book Reviews.” The Florida Tax Review is a faculty-edited law review published by the Graduate Tax Program of the University of Florida Levin College of Law, with the assistance of a number of Graduate Tax Students who assist the faculty editorial board. The Florida Tax Review prefers electronic submissions in Microsoft Word sent via ExpressO (law.bepress.com/expresso). Articles may be e- mailed to FTR@law.ufl.edu. If a hard copy submission is necessary, please mail your article to: Editor, Florida Tax Review, University of Florida Levin College of Law, P.O. Box 117634, Gainesville, FL 32611-7634. Although the Florida Tax Review has no minimum or maximum page requirements for submissions, it does have a strong preference for submissions that are 30,000 words or less, including text and footnotes. The Florida Tax Review will consider manuscripts at any time. All citations should follow The Bluebook: A Uniform System of Citation (20th ed.); however, some modifications will be made by our editors to conform with the Florida Tax Review Styles Manual. For submissions made directly to the Florida Tax Review, the Board of Editors will endeavor to decide within three weeks whether to publish a manuscript. After the decision has been made to publish, the Florida Tax Review is committed to expediting publication. All tax law and policy positions presented are solely those of the authors. The Editors and the University of Florida Levin College of Law do not approve of or adopt such positions merely through the act of publishing the manuscripts in the Florida Tax Review. FLORIDA TAX REVIEW Volume 19 2016 Number 9 All references and citations to sections in this issue are to sections of the Internal Revenue Code of 1986, as amended, unless otherwise indicated. All references and citations to regulations are to Treasury Regulations under the Internal Revenue Code of 1986, as amended, unless otherwise indicated.