"Section 1411 of the Internal Revenue Code was inserted into the income tax system unannounced as an income tax. On the contrary, it was named as if it were a part of Medicare, and placed within the second of the two distinct acts which together have come to be called, colloquially, the Affordable Care Act.... [N]one of the proceeds of the tax are dedicated to the purposes of the [ACA], none of those revenues flows into the Medicare funds or contributes to Medicare in any way (its nomenclature as a 'Medicare contribution' notwithstanding), nor would section 1411 in any way impact the heath care provisions of the ACA were the tax to be repealed or ruled unconstitutional.... Little has been said in the legal literature, let alone in the broad press, op-ed commentary or public print generally, of the enormous complexity that this new statute has injected into the tax law of the Nation, and the inevitably resultant errors that will abound in all the places where its application will occur."

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