Internal revenue

“ The congressional purpose to tax all stockholders who receive distributions of corporate earnings and profits cannot be frustrated by any reorganization which leaves earnings and profits undistributed in whole or in part. ”

“ Commissioner of Internal Revenue, supra, must be deducted from the taxpayer's initial investment in the asset in order to arrive at a depreciable 'net investment.' I use the word 'investment' rather than 'cost' because 'cost' may have so many different meanings, both to the accountant and to the tax lawyer, and some of those meanings would do considerable violence to the congressional purpose for depreciation allowances.↑ Useful life is to reflect the realities of the taxpayer's actual experience rather than a possibly unrealistic conceptualized idea of inherent physical life. Massey Motors v. ”

“ Absent substantial additional evidence, [11] furnishing management and other services to corporations for a reward not different from that flowing to an investor in those corporations is not a trade or business under § 23 (k) (4) . ”

“ Briefly stated, in the case of a distribution to a corporation with a deficit from either current or prior losses, the corporation receiving the distribution has no taxable income or earnings or profits available for current distribution until current income excees current losses, and no accumulated earnings or profits until its actual deficit from prior losses is erased. ”

“ There the people heard the list of fines levied in the courts; of tolls in the market, or taxes taken at the gates or in the harbour; of the “maltodes,” or sums paid on commodities for sale; of the “scot” levied on the property of individuals; of the “lyvelode” or livelihood, an income tax on rates or profits earned. They learned what means the corporation had taken of increasing the common revenue ”

“ The chief source of revenue is from indirect taxes, which bring nearly 10,000,000, while the greatest expenditure is for the payment of the interest on the debt, which with the sinking fund demands upward of 7,000,000. ”

“ The revenue involves not only the supply of the treasury with money, but the question of protection to manufactures. On these connected subjects, therefore, Gentlemen, as I have promised to keep nothing back, I will state my opinions plainly, but very shortly.
I am in favor of such a revenue as shall be equal to all the just and reasonable wants of the government; and I am decidedly opposed to all collection or accumulation of revenue beyond this point. An extravagant government expenditure, and unnecessary accumulation in the treasury, are both, of all things, to be most studiously avoided. ”

“ The fact that its measure is gross revenue is consistent with a tax on the privilege of doing a volume of business which would yield that revenue, just as the Legislature indicated. But we have declined to regard mere gross receipts as a sound measure of going-concern value in a practical world of commerce, where values depend on profitableness of a business, not merely its volume. ”

“ It is my wish that the collection of the revenue should be organised on a strictly business basis, with the same guarantees for efficiency and fidelity in the selection of the chief and subordinate officers that would be required by a prudent merchant. ”

“ The wealth of the state consists in the fortune of its members. The actual revenue of the state is that share of every private fortune, which the public has been accustomed to demand for national purposes. This revenue cannot be always proportioned to what may be supposed redundant in the private estate, but to what is, in some measure, thought so by the owner; and to what he may be made to spare, without intrenching on his manner of living, and without suspending his projects of expense, or of commerce. ”

“ Now industrial revenues come not only from the rents of forests, mines, docks, lands, and buildings, but from profits in the operation of industrial enterprises such as waterworks, railways, mines, and factories, and from interest on funds deposited in banks or otherwise invested. At present the industrial revenues of the aggregate governments of the United States (national, state, and municipal) amount to about a fifth of all revenue receipts. ”

“ The chief sources of revenue are direct taxes, indirect taxes, customs duties, post and telegraph and post-office savings banks receipts, railway receipts, and profits or royalties on forests, domains and mining. ”

“ The next risk with a commercial company like ours would be the question of the cost of administration. You might very fairly say, ‘We know that the future is all right. We feel that so huge a country, mineralised like that, must come out successfully; but what is the cost of administration, what is the difference between revenue and expenditure?’ That is the next question which business men would ask. In connection with that you will no doubt have examined the reports, but it is always very difficult to obtain a practical idea from a report, respecting a question like this. ”

“ And on the same principle a note given for a wager on the future amount of a branch of the public revenue is declared void; because it interests an individual in diminishing the production of the revenue. ”

“ In revenue, it has, since the year 1789, yielded one hundred and ninety-one millions of dollars. During the first four years after the commencement of the present government, the revenue averaged only about two millions annually; during a subsequent period, of four years, it rose to an average of fifteen millions, annually, or became equivalent to a capital of two hundred and fifty millions of dollars, at an interest of six per centum per annum. And if our commerce is reëstablished, it will, in the course of time, net a sum for which we are scarcely furnished with figures, in arithmetic. ”

“ The payments which have been made into the Treasury show the very productive state of the public revenue. ”

“ Wages, profit, and rent, are the three original sources of all revenue, as well as of all exchangeable value. All other revenue is ultimately derived from some one or other of these.
Whoever derives his revenue from a fund which is his own, must draw it either from his labour, from his stock, or from his land. The revenue derived from labour is called wages; that derived from stock, by the person who manages or employs it, is called profit; that derived from it by the person who does not employ it himself, but lends it to another, is called the interest or the use of money. ”

“ It is common to speak of two kinds of revenue. That which we have mentioned,—the profits of capital,—is called neat revenue; while the name of gross revenue is given to the whole return made to the capitalist; that is, his reproduced capital and his profits together make his gross revenue, and his profits alone make his neat revenue. ”

“ The lowest rate, he tells us, at which advances used to be obtained from capitalists, even upon the land-tax, which seems to have been considered the surest part of the national revenue, was eight per cent., although repayment was made within the year, and premiums were generally granted to the subscribers. On anticipations of other taxes, counting premiums, discount, and interest, the public had sometimes to pay twenty, thirty, and even forty per cent. ”

“ The ownership of this vast property is represented by stocks and bonds aggregating $9,000,000,000. They receive yearly from the public for carrying passengers and freights the sum of $1,000,000,000 and, after paying the expenses of their operation, including the wages of more than 1,000,000 employés, they have left an available revenue of $415,000,000. More than one of the larger companies has a revenue greater than that of the United States government was thirty years ago. To earn this enormous sum the roads work night and day, seven days a week. ”

“ The public revenue is derived from the custom duties, direct taxes on property, licenses to trade houses, stamped paper, stamps, import and export duties, port dues, municipal duties in the capital and in the departments, duties on indirect inheritance, trade patents, cattle marks, etc. ”

“ The cash balance in the Treasury at the end of the fiscal year it is estimated will be $20,992,377.03. So far as these figures are based upon estimates of receipts and expenditures for the remaining months of the current fiscal year, there are not only the usual elements of uncertainty, but some added elements. New revenue legislation, or even the expectation of it, may seriously reduce the public revenues during the period of uncertainty and during the process of business adjustment to the new conditions when they become known. ”

“ Fourteen millions, in taxes, and in the advanced prices which must follow, are one eighth of 112 millions revenue, which, by the necessary rise in the price of every thing, is carried to 126 millions. ”

“ Another source of revenue in British imperial finance is that from fees in courts of justice, patent stamps and the like, which is usually classified, like the income of the post office, as revenue derived from other sources than taxes. ”

“ In practice, the gross revenue is entered with other items of revenue in the National Accounts, and the gross expenditure with other items of general and non-productive expenditure, with the result that the net profits of the Post Office, in effect, become a source of general revenue, and are therefore applied in reduction of general taxation. ”

“ When, by different taxes upon the necessaries and conveniences of life, the owners and employers of capital stock find that whatever revenue they derive from it will not, in a particular country, purchase the same quantity of those necessaries and conveniences which an equal revenue would in almost any other, they will be disposed to remove to some other. ”

“ Moreover, the present method of collecting revenue under the income tax is speculative and uncertain, because the profits of industry and business, upon which the income tax is based, are subject to vast fluctuations. ”

“ Revenue and the expenditure of revenue form by far the most important element in the government of modern nations. Revenue is not, as some one has said, the friction of a government, but rather its motive power. Without it the machinery of a government can not move; and by it all the movements of a government are regulated. The expenditure of revenue forms the grand level from which all heights and depths of legislative action are measured. The increase and the diminution of the burdens of taxation depend alike upon their relation to this level of expenditures. ”

“ The net output thus obtained is obviously for each industry the only fund from which first, wages, salaries, interest on capital, rent, royalties and profits are, or can be, paid, and secondly, taxes, rates, depreciation, advertisement and sales expenses. ”

“ The government must have a certain amount of revenue, and that amount must be collected from the imports. Is it material to the consumer, wherever situated, whether the collection be made upon a few, or many objects, provided, whatever be the mode, the amount of his contribution to the public exchequer remains the same? If the assessment can be made on objects which will greatly benefit large portions of the union, without injury to him, why should he object to the selection of those objects? ”

“ By it the taxes were imposed not for the legitimate purpose of raising revenue, but to afford advantages to favored classes at the expense of a large majority of their fellow-citizens. Those employed in agriculture, mechanical pursuits, commerce, and navigation were compelled to contribute from their substance to swell the profits and overgrown wealth of the comparatively few who had invested their capital in manufactures. ”

“ If then we show by the undertaking of such a work as is now proposed, the balance sheets of the merchants and manufacturers must increase immensely, we surely make out a case for the good of the country generally, as far as revenue is concerned. ”

“ It cannot be said that there is anything like a system in the actual distribution of revenue sources between the two forms of government. It must, however, be obvious that the orderly development of each requires that well-defined sources of income be assigned in such a way as to satisfy the more rapidly increasing necessities of the local governments.
A revenue system should therefore supply current needs, should increase in productiveness as those needs increase, and should moreover be regular in its returns and capable of meeting the fluctuations of financial necessities. ”

“ I need not add that this important measure is now (1869) on the point of being carried into effect, but must regret that it should be at a cost at once so superfluous and so enormous as to make it very doubtful whether the institution can be self-supporting (that is, paying at once interest on money borrowed, its direct working expenses, and a just [252] contribution to the general cost of management) , and almost certain that, save at further loss to the revenue, correspondence by its means cannot be cheap. [119]
FOREIGN EXTENSION. ”

“ Upon the organization of a new enterprise the distinction between capital and revenue expenditures can usually be made without much difficulty. All costs incurred to put the concern in a position to earn revenue are properly treated as capital expenditures. Sufficient capital must be provided to put the undertaking on an earning basis, as otherwise it fails. These costs will include many items which upon their second incurrence must be treated as expense charges because the revenue must provide for keeping the plant in a state of efficient repair. ”

“ A revenue, Charlie, is the income or yearly sum of money of a State, raised from taxes on the people or their property, from duties on foreign merchandise imported into the country, and from the sale of public lands and other sources, to meet the expenses of the government. A remonstrance, Bryce, is a setting-forth in strong terms, either by writing or by word of mouth, the facts and reasons against something complained of or opposed, as unjust, unwise, or unadvisable. ”