"The Moore opinions make it clear that at least four Justices are prepared to hold that realization is constitutionally required, and there is reason to believe that were the constitutionality of section 877A to come before the Court, a majority would uphold the realization requirement.“
Mark E. Berg was quoted in the Tax Notes article “‘Bitcoin Jesus’ Cites Loper and Uncertainty in Tax Crime Defense” on December 5, 2024.
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