Harlan F. Stone

“ Experience demonstrating that income derived from merchandising and manufacturing businesses could not be computed on the basis of receipts and disbursements alone, treasury regulations were promulgated requiring the use of inventories in proper cases, and permitting the deduction of accounts payable when accounts receivable were brought into the income account. ”

“ By section 13 (b) of the 1916 act, which was new, the return in every case is required to state such data as are 'appropriate and in the option of the commissioner necessary to determine the correctness of the net income returned and to carry out the provisions of this title.' It follows that the return must be filed on the accrual basis under section 13 (d) , where true income cannot be arrived at on the basis of actual receipts and disbursements. ”

“ This Court has often affirmed: 'In the interpretation of statutes levying taxes it is the established rule not to extend their provisions, by implication, beyond the clearimport of the language used, or to enlarge their operations so as to embrace matters not specifically pointed out. In case of doubt they are construed most strongly against the government, and in favor of the citizen.' Gould v. ”