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The 1231 part of this article seems to have originated with a single law professor (Infanti) at Pitt, who uses the term to refer to his own version of the process of determining taxability of 1231 gains. Can anyone else find references anywhere to this? Note that if you search the web, you'll find several instances of this Wikipedia article being quoted verbatim. Neither code, regs, nor tax cases I can search contain this word at all. I do find reference in Virginia family law, which is hardly relevant to Federal tax law. I recommend deleting the tax section of this article. Oldtaxguy (talk) 02:37, 17 August 2010 (UTC)
The casebook Federal Income Taxation by Graetz & Schenk use the term. --126.96.36.199 (talk) 21:54, 15 December 2011 (UTC)