This Article originally appeared in The Tax Lawyer, Vol. 44, No. 3 (1991) and is reprinted here in its original form in remembrance of the author, Hugh Calkins, and in recognition of the timeless issues he continued to study after he retired from the practice of law and that continue to provoke thoughts about tax policy today. Hugh Calkins passed away in August 2014, and a memoriam appears at the beginning of this issue. At the time this Article was written, he was a retired partner in the Cleveland office of Jones Day. He served as Chair of the ABA Tax Section in 1985–86.