Are Unrealized Gains Income? 

That remains the key question as it is a method Democrats have chosen to pay for Biden's Build Back Better Plan.

I covered the issue at great length in The Meaning of "Income" Suddenly Becomes Very Important For Tax Purposes

There are a couple of different interpretations of "income" but my bottom line opinion remained was as follows

"The proposal taxes unrealized gains. But is there income before gains are realized? The courts will decide if this goes forward, but the idea is dubious at best."

I also discussed why the method was unwise even if the idea was constitution. I failed to go over actual Supreme Court tax cases which I am now aware of.