Just on the multiple taxation issue:  all the money in circulation has
been taxed many times.  That doesn't mean future transfers shouldn't be
taxed.  The argument about multiple taxation has force when the ultimate
recipient of the money seems to have had a claim on it at the time the
first tax was imposed.  Shareholders own a corporation; they own the
money it earns, on which it pays taxes.  Should they have to pay a tax
again when that money is distributed to them?  This is plausibly
described as double taxation.  When I earn money and pay tax on it, then
use my after tax earnings to pay a lawyer (for example), it doesn't look
like double taxation to require her to pay tax.  So the question of
whether the inheritance tax is an instance of  double taxation comes
down to the question of whether children have this sort of pre-existing
claim on a parent's wealth.  You can take this as a question directed
either to your philosophical intuitions, or to our current legal system,
but in either case  I don't think it's preposterous to say the answer is
no.

Eastman, John wrote:

Cornell Clayton's position below really is preposterous.  Talk about
double taxation -- the money left via a will has already been taxed, of
course (often several times!).  I'm curious, though, how far he would go
with it.  If I give my kids $100,000 over 4 years for college tuition,
would he tax that as "income" to my kids?  How about room and board for
the 18 years before that?

But to bring this back to constitutional law.  Are there any
constitutional limits on the taxing power at all?  Anything to prevent a
90 or 100% confiscatory estate tax?  In the Federalist 10, James Madison
counted it "the first object of government" to protect the diversity in
the faculties of men, from which the rights of property originate.  Is
there anything in the Constitution that is designed to further this
purpose?

John C. Eastman
Professor of Law, Chapman University School of Law
Director, The Claremont Institute Center for Constitutional
Jurisprudence


-----Original Message----- From: Cornell Clayton [mailto:[EMAIL PROTECTED] Sent: Friday, May 23, 2003 12:58 PM To: [EMAIL PROTECTED] Subject: Re: Statistics


Glenn Reynolds wrote:


2.  It would be ironic, if people's right to pass their property on to
their descendants were generally regarded as unfair and illegitimate.



I, for one, do think that laws allowing inheritance of massive amounts
of property or wealth (or economic advantage) are unfair and
illegitimate. Following a Rawlsian conception of equality -- which I
believe is the best interpretation of our constitutional commitment to
equality -- I can see no difference theoretically between one inheriting
arbitrary advantages (or
disadvantages) on the basis of birth-family as opposed to color of skin.
One does nothing to merit either one, so one has no more just
expectation to inherit privilege on the basis of the family you are born
into than to inherent privilege on the basis of the skin color you
happen to be born with.  This is one of the reasons I think the
Republican attack on the
estate tax is so egregious.   It is not a "death tax", but a tax on
income
that is not deserved or merited!  Not only should we not eliminate the
estate tax, we should tax inheritance at a much higher level than earned
income.

Of course, I readily concede Glen's other point, that as a matter of
history (as opposed to theory) the US experience with race
discrimination is quite different than thinking about  problems created
by economic inheritance.

Cheers,
Cornell Clayton


-- Kermit Roosevelt Assistant Professor University of Pennsylvania Law School 3400 Chestnut Street Philadelphia PA 19104 215.898.5185

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