Document Type

Student Article


The tax characterization of income from human body transfers is a perplexing conundrum. There is no definitive case law or statute that informs taxpayers how to treat these transfers. Legal scholars have discussed the issue of how to treat human body transfers such as eggs, sperm, blood, etc. for decades, and the Internal Revenue Service has still not acted to provide any sort of clarity. This Comment discusses the historical tax implications on various types of human body transfers, outlines some of the distinguishing factors between characterizing a transfer as property or a service, provides an argument for why income from egg donation should be characterized as a service, and finally, discusses how a definitive characterization will affect the regulation of egg donation and lead to an increase in the research of overall health effects from egg donation.



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