Tax Notes Federal 2023 Persons Of The Year: Kathleen And Charles Moore

Marie Sapirie, Persons of the Year: The Moores: The Constitution, Realization, and Two Tax Everymen, 181 Tax Notes Fed. 2091 (Dec. 18, 2023):

Every tax practitioner and many readers of editorial pages will recognize their names today, but that wasn’t true until recently. For their role as petitioners in the most highly analyzed and anticipated Supreme Court tax case of the year, Kathleen and Charles Moore are the Tax Notes Federal People of the Year. ...

The Moores are among the few Tax Notes Federal People of the Year in recent years who aren’t tax professionals or elected officials. They’re Everyman taxpayers who have taken the stage — by their admission, reluctantly — in the increasingly worldwide drama of modern tax law. Kathleen recounted in the video her memory of receiving the IRS’s deficiency letter, an experience shared by many taxpayers each year: “Well, it’s never good to get something in the mail from the IRS. It makes your heart pound.” And then she admitted that she wasn’t sure she wanted to be a litigant against the IRS. Certainly, very few would relish that role. ...

Charles explained his motive for taking up the mantle of the Everyman taxpayer: “We are doing this because we strongly believe in the rule of law of this country.” He said he hopes the Supreme Court ultimately says, “Right, this is not constitutional. The Moores have not received any income. How can they be taxed if they have not received any income?” The Court will render its answer next year.

Tax Notes State Person of the Year
Gil Brewer (Senior Assistant Director for Tax Policy, Washington Department of Revenue)

Tax Notes International Person of the Year
Michael Lennard (Chief, International Tax Cooperation & Trade, Financing for Development Office (FfDO), United Nations)

Prior TaxProf Blog coverage:

• Christopher Cox (Former Rep. (1989-2005) & SEC Chair (2005-2009)) & Hank Adler (Chapman), The Ninth Circuit Upholds A Wealth Tax (Jan. 30, 2023)
• Reuven Avi-Yonah (Michigan), If Moore Is Reversed, 179 Tax Notes Fed. 2215 (June 26, 2023)
• John Brooks (Fordham) & David Gamage (Indiana), Moore v. United States and the Original Meaning of Income (June 27, 2023) (reviewed by Michelle Layser (San Diego) here) (presented at Columbia workshop)
• Daniel Hemel (NYU), The Low And High Stakes Of Moore, 180 Tax Notes Fed. 563 (July 24, 2023) (reviewed by Young Ran (Christine) Kim (Cardozo) here)
• Alex Zhang (Emory), Moore, Eisner v. Macomber, and the Future of Structural Tax Reform, 92 Geo. Wash. L. Rev. __ (2024) (Aug. 29, 2023)
• Joseph J. Thorndike (Tax Analysts), Moores Lean On 1916 Tax Expert To Argue No Realization Means No Income
• Thomas Lee (BYU), Lawrence Solum (Virginia), James Cleith Phillips (Chapman) & Jesse Egbert (Northern Arizona), Moore, Corpus Linguistics, And The Original Public Meaning Of The Sixteenth Amendment (Sept. 14, 2023)
• Reuven Avi-Yonah (Michigan), Moore Questions Than Answers, 180 Tax Notes Fed. 2256 (Sept. 25, 2023)
• Christopher Hanna (SMU), Moore, The 16th Amendment, And The Underpinnings Of The TCJA’s Deemed Repatriation Provision (Sept. 28, 2023) (reviewed by Mirit Eyal-Cohen (Alabama) here)
• Joint Committee on Taxation, Tax Code Provisions Implicated In Moore (Oct. 3, 2023)
• Natasha Sarin (Yale), The Supreme Court Tax Case That Could Blow A Hole In The Federal Budget (Oct. 7, 2023)
• John Brooks (Fordham) & David Gamage (Indiana), “From Whatever Source Derived”: The Sixteenth Amendment and Congress’s Income Tax Power (Oct. 9, 2023) (reviewed by David Elkins (Netanya) here and Blaine Saito (Ohio State) here) (presented at Loyola-L.A. workshop and San Diego workshop)
• Steven Rosenthal (Tax Policy Center), Moore Could Invalidate Decades Of Tax Rules, 181 Tax Notes Fed. 285 (Oct. 9, 2023)
• Lawrence Zelenak (Duke), Reading The Taxpayers’ Brief In Moore (Oct. 18, 2023)
• NYU Tax Law Center, Guide To Moore (Oct. 25, 2023)
• Blaine Saito (Ohio State), Review Of  “From Whatever Source Derived”: The Sixteenth Amendment and Congress’s Income Tax Power, by John Brooks (Fordham) & David Gamage (Indiana) (Oct. 27, 2023)
• Tax Prof Amicus Briefs In Moore v. United States, 23 For Government, 1 For Taxpayer (Oct. 31, 2023)
• Steven Calabresi (Northwestern), Moore: Taxes On Wealth And Unrealized Capital Gains Are Unconstitutional (Nov. 1, 2023)
• Michael Graetz (Columbia), To Avoid The Moore Morass, The Court Should DIG It (Dismiss As Improvidently Granted), 181 Tax Notes Fed. 1253 (Nov. 13, 2023)
• Taxpayer's Reply Brief In Moore v. United States, 'Macomber Decided The Question Of Realization, Decided It Correctly, And That Holding Remains Good Law' (Nov. 17, 2023)
• Steven Calabresi (Northwestern), Amar Brothers' Moore Amicus Brief Ignores Constitution's Plain Meaning To Justify Taxing Unrealized Gains (Nov. 25, 2023)
• Listen To Moore v. United States Supreme Court Oral Argument Today At 10:00 AM ET (Dec. 5, 2023)
• Hot Takes On Yesterday's Moore v. United States Supreme Court Oral Argument (Dec. 6, 2023)
• More Reaction To The Supreme Court Oral Argument In Moore v. United States (Dec. 8, 2023)
• Joseph Fishkin (UCLA) & William E. Forbath (Texas), Moore, The Rich, And The Supreme Court (New York Times Op-Ed) (Dec. 12, 2023)
• Conor Clarke (Washington University), What Issues Are Fair Game In Moore v. United States?, 40 Yale J. on Reg.: Notice & Comment (Dec. 16, 2023)
• Seven Tax Experts, The Biggest Implications Of Moore v. United States, 181 Tax Notes Fed. 2147 (Dec. 18, 2023)