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Abstract: Whether to tax virtual income raises a exing question. Most people’s intuition suggests that virtual income should be exempt from tax, but the real-world economic value inherent in such income suggests otherwise. Those who have considered the question to date have attempted to justify non-taxation using either an intent-based or imputed-income approach. In this Article, I argue that neither of these approaches nor the proposals they produce are fully satisfactory. Using the ability-to-pay principle, I offer a new approach to this question,which better conforms to existing tax policy and doctrine and produces a more administrable proposal than those made to date.
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