The Board of Tax Appeals and Corporation Affiliation

The inauguration of a Federal system of income taxation, under the Sixteenth Amendment to the Constitution of the United States, by the Revenue Act of 1913, brought into existence a new and important branch of the law. The Revenue Act of 1913 contained but few provisions relative to the substantive matter of income tax. In the formulation of the four successive Revenue Acts of 1916, 1917, 1918 and 1921, legislative attention was directed of necessity to those provisions clarifying and amplifying the substantive matter of income, excess and war profits taxes. Little consideration was given to the administrative provisions of the law until the Revenue Act of 1921 came into force on January 1, 1921. The 1921 Act contained many desirable provisions relative to the administration of the tax laws.After fifteen years of administration of the income tax law, it is surprising to find that in applying it to modern business, conditions are so varied and complex that not a single day goes without presenting a new grist of income, tax problems only remotely related to those already decided. The ultimate success of the income tax depends upon taking it out of the realm of litigation and handling it as an administrative matter, without forcing such a vast number of cases into the courts or bodies like the Board of Tax Appeals.