Pillar

Open Questions

Where the doctrine is genuinely unresolved or contested — circuit splits, internal inconsistencies, conclusions asserted without reasoning.

Places where the doctrine doesn’t cohere and no honest verdict is possible yet.

Essays

Doctrine Unresolved

What "Income" Means — and Why a Century of Case Law Hasn't Settled It

The Sixteenth Amendment uses 'income' without defining it. Eisner v. Macomber tried. Commissioner v. Glenshaw Glass tried again. Neither fully succeeded. The resulting ambiguity is not a conspiracy — it's a real doctrinal gap with real consequences.

18 min read May 4, 2026

Findings

Unresolved Whether Glenshaw Glass expanded "income" beyond the original constitutional meaning Apr 20, 2026 · 6 min