Professor Adam Chodorow has published an article, "Ability to Pay and the Taxation of Virtual Income," in the Tennessee Law Review. In it, he melds the worlds of cyberspace and tax law, noting the extraordinary real-world economic value of virtual income, and arguing that it is wrong-headed to classify such income as outside the tax system.
Chodorow argues that, if an individual can derive real-world income from virtual income, he or she has the ability to pay taxes on it, and it therefore should be taxed. In considering the practical difficulties of that determination, he proposes the IRS designate ahead of time that virtual worlds are either "closed" or "open," based on the ability to "cash out."
Click here to read the article.
Chodorow's research and teaching interests lie in tax, administrative and regulatory law. He teaches a variety of tax courses, as well as Law and the Regulatory State. His research focuses on religious taxation and a variety of contemporary tax issues, such as the taxability of virtual income.