San Diego Law Review


Fred B. Brown

Library of Congress Authority File


Document Type



This Article considers and analyzes "complete" accrual taxation, the inclusion in the tax base of annual increases and decreases in the value of property, regardless of disposition. This system does away with the rule that income must be realized in order to be taxed. The Article outlines the complete tax accrual system and engages in a rigorous examination of the benefits resulting from such a system. It compares the consequences of such a system to the consequences of adopting other alternatives to the realization rule. It explores a computerized valuation system for nonmarketed business interests, and deals with legitimate privacy concerns raised by such a system. The author concludes by noting that complete accrual taxation is beneficial and feasible, and that further research should be done to address these issues.

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