INTRODUCTION TO TAX SCHOOL

Slides:

Advertisements

Similar presentations

Chapter 11 Accounting Periods and Methods. Learning Objectives Explain the rules for adopting and changing an accounting period Explain the differences.

Advertisements

©The McGraw-Hill Companies, Inc. 2008McGraw-Hill/Irwin Chapter 1 Introduction to Taxation, the Income Tax Formula, and Form 1040EZ “Taxes, after all, are.

Chapter 01 Introduction to Taxation, the Income Tax Formula, and Form 1040EZ “Taxes, after all, are dues that we pay for the privileges of membership in.

Income Tax concepts: General Concepts Ability to pay concept

In the Constitution Section 1. The Judicial Power of the United States, shall be vested in one supreme Court, and in such inferior courts as the Congress.

Local taxes Direct taxes (no ability to be avoided) 1- income taxes 2- property taxes Indirect taxes (can be avoided in some cases) 1- customs taxes 2-

Chapter 7: The Judicial Branch

Cash and Carried Interests: Protecting the Investor and Developer in a Real Estate Partnership Howard E. Abrams Of Counsel, Steptoe & Johnson LLP Professor,

The Concepts of Income and Deductions Tx Lecture Overview  Income  Gross Income  Taxable Income  Deductions.

Chapter 7: The Judicial Branch. “The Federal Court System & How Federal Courts Are Organized”

“The Federal Court System & How Federal Courts Are Organized”

Current Supreme Court Early History Early in the life of the United States, the Supreme Court had little true power. It heard very few cases each year.

Annual Accounting: Burnet v. Sanford & Brooks A dispute with the government over a contract to dredge river. Did company make or lose money on the contract.

Chapter 12 Accounting for Receivables. 2 Receivables... Amounts due from individuals and companies - expected to be collected in cash. Frequently classified.

Pp  Two things to notice:  1. revenues are normally credited  2.drawings and expenses are normally debited  Revenues bring assets into a.

The Accrual Method of Accounting. Georgia School-Book Depository.

PG CH. 14: THE CONGRESS, THE PRESIDENT, & THE BUDGET: THE POLITICS OF TAXING & SPENDING.

Federal Estate and Income Taxes

The facts on taxes… Who pays the most taxes?

Introduction Income Tax

PTAX Personal Taxation

Chapter 2 Income Tax Concepts Kevin Murphy Mark Higgins

Accounts Receivable Using examples, we will walkthrough

Judicial Branch – Supreme Court

FINANCIAL CALCULATIONS FOR LAWYERS

INTRODUCTION TO TAX SCHOOL

Tax Planning Strategies and Related Limitations

Special Property Transactions

The Federal Court System

The United States Supreme Court

The Purpose of Accounting

How tax is calculated on your Taxable income Example Your gross income = $126,000 Your deduction = $ 6,000 Taxable income = $120,000.

Hosted by Ms. Appel.

Special Property Transactions

Penalty Tax and Tax Offences

Chapter 8, Section 3 The United States Supreme Court

INTRODUCTION TO TAX SCHOOL

Tax Lesson 20 YOURLOGO Start Lecture

ACCOUNTING FOR SALES AND CASH RECEIPTS

The Federal Court System

Income tax and Deferred tax

Lesson 2-Continued.

The Federal Court System

The Inferior Courts.

Introduction Income Tax

Penalty Tax and Tax Offences

IAS 12. What is an Income Tax? An income tax is a tax that governments impose on income generated by businesses and individuals within their jurisdiction.

Chapter 12 Partnership Distributions

Understanding Principles of Accounting

Tax on Revenues of commercial And industrial activities

Chapter 27/ Chapter 25 ________________ Investing in Real Estate

INTRODUCTION TO TAX SCHOOL

U.S. Supreme Court.

How the Federal Gov’t Works: The Judicial Branch

Requirements for Deductibility of Bad Debts

Chapter 2 Income Tax Concepts Murphy & Higgins

S Corporation Built-in Gains Tax Rules Summary and Illustrations

INTRODUCTION TO TAX SCHOOL

INTRODUCTION TO TAX SCHOOL Top 100 Cases

VAT Module 10 (b) VAT Administration and Compliance

Presentation transcript:

INTRODUCTION TO TAX SCHOOL Top 100 Cases Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) Sanford & Brooks stands for one important proposition: This proposition is conjunction with two other famous cases: North American Oil v. Burnet, 286 U.S. 417 (1932) U.S. v. Lewis, 340 U.S. 590 (1951). © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) Sanford & Brooks stands for one important proposition: This proposition is conjunction with two other famous cases: North American Oil v. Burnet, 286 U.S. 417 (1932) U.S. v. Lewis, 340 U.S. 590 (1951). Every year stands alone. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) Sanford & Brooks stands for one important proposition: This proposition is conjunction with two other famous cases: North American Oil v. Burnet, 286 U.S. 417 (1932) U.S. v. Lewis, 340 U.S. 590 (1951). Every year stands alone. Another way of saying this is that the United States uses annual rather than transactional accounting. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) Sanford & Brooks stands for one important proposition: This proposition is conjunction with two other famous cases: North American Oil v. Burnet, 286 U.S. 417 (1932) U.S. v. Lewis, 340 U.S. 590 (1951). Every year stands alone. Another way of saying this is that the United States uses annual rather than transactional accounting. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) Sanford & Brooks stands for one important proposition: This proposition is conjunction with two other famous cases: North American Oil v. Burnet, 286 U.S. 417 (1932) U.S. v. Lewis, 340 U.S. 590 (1951). Every year stands alone. Another way of saying this is that the United States uses annual rather than transactional accounting. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) Sanford & Brooks stands for one important proposition: This proposition is conjunction with two other famous cases: North American Oil v. Burnet, 286 U.S. 417 (1932) U.S. v. Lewis, 340 U.S. 590 (1951). Every year stands alone. Another way of saying this is that the United States uses annual rather than transactional accounting. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) Sanford & Brooks stands for one important proposition: This proposition is conjunction with two other famous cases: North American Oil v. Burnet, 286 U.S. 417 (1932) U.S. v. Lewis, 340 U.S. 590 (1951). Every year stands alone. Another way of saying this is that the United States uses annual rather than transactional accounting. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) Sanford & Brooks stands for one important proposition: This proposition is conjunction with two other famous cases: North American Oil v. Burnet, 286 U.S. 417 (1932) U.S. v. Lewis, 340 U.S. 590 (1951). Every year stands alone. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) Sanford & Brooks stands for one important proposition: This proposition is conjunction with two other famous cases: North American Oil v. Burnet, 286 U.S. 417 (1932) U.S. v. Lewis, 340 U.S. 590 (1951). Every year stands alone. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) Sanford & Brooks stands for one important proposition: This proposition is conjunction with two other famous cases: North American Oil v. Burnet, 286 U.S. 417 (1932) U.S. v. Lewis, 340 U.S. 590 (1951). Every year stands alone. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) Sanford & Brooks stands for one important proposition: This proposition is conjunction with two other famous cases: North American Oil v. Burnet, 286 U.S. 417 (1932) U.S. v. Lewis, 340 U.S. 590 (1951). Every year stands alone. These two cases are also on the top 100 list. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) FACTS: Company did work for United States during 1913-16. Company had net losses during these years of $176,271.88 In 1916, the company sued the U.S. for the money. In 1920, it collected the $176,271.88 plus interest.1920: ISSUE: How should the company report the recovery? Is it income when received? Should the company amend the prior returns to remove the deducted losses? HOLDING: The $176,271.88 was income on receipt. The prior years correctly reported losses. Amendment of them would be inappropriate. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) FACTS: Company did work for United States during 1913-16. Company had net losses during these years of $176,271.88 In 1916, the company sued the U.S. for the money. In 1920, it collected the $176,271.88 plus interest.1920: ISSUE: How should the company report the recovery? Is it income when received? Should the company amend the prior returns to remove the deducted losses? HOLDING: The $176,271.88 was income on receipt. The prior years correctly reported losses. Amendment of them would be inappropriate. Note: The case arose very early in our tax system: the 16th Amendment authorizing the income tax became effective in 1913. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) FACTS: Company did work for United States during 1913-16. Company had net losses during these years of $176,271.88 In 1916, the company sued the U.S. for the money. In 1920, it collected the $176,271.88 plus interest.1920: ISSUE: How should the company report the recovery? Is it income when received? Should the company amend the prior returns to remove the deducted losses? HOLDING: The $176,271.88 was income on receipt. The prior years correctly reported losses. Amendment of them would be inappropriate. Note: The case arose very early in our tax system: the 16th Amendment authorizing the income tax became effective in 1913. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) FACTS: Company did work for United States during 1913-16. Company had net losses during these years of $176,271.88 In 1916, the company sued the U.S. for the money. In 1920, it collected the $176,271.88 plus interest.1920: ISSUE: How should the company report the recovery? Is it income when received? Should the company amend the prior returns to remove the deducted losses? HOLDING: The $176,271.88 was income on receipt. The prior years correctly reported losses. Amendment of them would be inappropriate. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) FACTS: Company did work for United States during 1913-16. Company had net losses during these years of $176,271.88 In 1916, the company sued the U.S. for the money. In 1920, it collected the $176,271.88 plus interest.1920: ISSUE: How should the company report the recovery? Is it income when received? Should the company amend the prior returns to remove the deducted losses? HOLDING: The $176,271.88 was income on receipt. The prior years correctly reported losses. Amendment of them would be inappropriate. The company actually reported the losses on its tax returns during 1913-16. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) FACTS: Company did work for United States during 1913-16. Company had net losses during these years of $176,271.88 In 1916, the company sued the U.S. for the money. In 1920, it collected the $176,271.88 plus interest.1920: ISSUE: How should the company report the recovery? Is it income when received? Should the company amend the prior returns to remove the deducted losses? HOLDING: The $176,271.88 was income on receipt. The prior years correctly reported losses. Amendment of them would be inappropriate. The company actually reported the losses on its tax returns during 1913-16. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) FACTS: Company did work for United States during 1913-16. Company had net losses during these years of $176,271.88 In 1916, the company sued the U.S. for the money. In 1920, it collected the $176,271.88 plus interest.1920: ISSUE: How should the company report the recovery? Is it income when received? Should the company amend the prior returns to remove the deducted losses? HOLDING: The $176,271.88 was income on receipt. The prior years correctly reported losses. Amendment of them would be inappropriate. The company actually reported the losses on its tax returns during 1913-16. This reporting treatment was proper. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) FACTS: Company did work for United States during 1913-16. Company had net losses during these years of $176,271.88 In 1916, the company sued the U.S. for the money. In 1920, it collected the $176,271.88 plus interest.1920: ISSUE: How should the company report the recovery? Is it income when received? Should the company amend the prior returns to remove the deducted losses? HOLDING: The $176,271.88 was income on receipt. The prior years correctly reported losses. Amendment of them would be inappropriate. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) FACTS: Company did work for United States during 1913-16. Company had net losses during these years of $176,271.88 In 1916, the company sued the U.S. for the money. In 1920, it collected the $176,271.88 plus interest.1920: ISSUE: How should the company report the recovery? Is it income when received? Should the company amend the prior returns to remove the deducted losses? HOLDING: The $176,271.88 was income on receipt. The prior years correctly reported losses. Amendment of them would be inappropriate. Note: the company claimed the U.S. owed payment for the services equal to the losses. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) FACTS: Company did work for United States during 1913-16. Company had net losses during these years of $176,271.88 In 1916, the company sued the U.S. for the money. In 1920, it collected the $176,271.88 plus interest.1920: ISSUE: How should the company report the recovery? Is it income when received? Should the company amend the prior returns to remove the deducted losses? HOLDING: The $176,271.88 was income on receipt. The prior years correctly reported losses. Amendment of them would be inappropriate. Note: the company claimed the U.S. owed payment for the services equal to the losses. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) FACTS: Company did work for United States during 1913-16. Company had net losses during these years of $176,271.88 In 1916, the company sued the U.S. for the money. In 1920, it collected the $176,271.88 plus interest.1920: ISSUE: How should the company report the recovery? Is it income when received? Should the company amend the prior returns to remove the deducted losses? HOLDING: The $176,271.88 was income on receipt. The prior years correctly reported losses. Amendment of them would be inappropriate. Note: the company claimed the U.S. owed payment for the services equal to the losses. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) FACTS: Company did work for United States during 1913-16. Company had net losses during these years of $176,271.88 In 1916, the company sued the U.S. for the money. In 1920, it collected the $176,271.88 plus interest. ISSUE: How should the company report the recovery? Is it income when received? Should the company amend the prior returns to remove the deducted losses? HOLDING: The $176,271.88 was income on receipt. The prior years correctly reported losses. Amendment of them would be inappropriate. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) FACTS: Company did work for United States during 1913-16. Company had net losses during these years of $176,271.88 In 1916, the company sued the U.S. for the money. In 1920, it collected the $176,271.88 plus interest. ISSUE: How should the company report the recovery? Is it income when received? Should the company amend the prior returns to remove the deducted losses? HOLDING: The $176,271.88 was income on receipt. The prior years correctly reported losses. Amendment of them would be inappropriate. Both the taxpayer and the government agreed the interest was taxable in the year of receipt. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) FACTS: Company did work for United States during 1913-16. Company had net losses during these years of $176,271.88 In 1916, the company sued the U.S. for the money. In 1920, it collected the $176,271.88 plus interest. ISSUE: How should the company report the recovery? Is it income when received? Should the company amend the prior returns to remove the deducted losses? HOLDING: The $176,271.88 was income on receipt. The prior years correctly reported losses. Amendment of them would be inappropriate. Both the taxpayer and the government agreed the interest was taxable in the year of receipt. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) FACTS: Company did work for United States during 1913-16. Company had net losses during these years of $176,271.88 In 1916, the company sued the U.S. for the money. In 1920, it collected the $176,271.88 plus interest. ISSUE: How should the company report the recovery? Is it income when received? Should the company amend the prior returns to remove the deducted losses? HOLDING: The $176,271.88 was income on receipt. The prior years correctly reported losses. Amendment of them would be inappropriate. Both the taxpayer and the government agreed the interest was taxable in the year of receipt. Depending on the company’s method of accounting plus various time value of money provisions, this may – or may not – be true today. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) FACTS: Company did work for United States during 1913-16. Company had net losses during these years of $176,271.88 In 1916, the company sued the U.S. for the money. In 1920, it collected the $176,271.88 plus interest.1920: ISSUE: How should the company report the recovery? Is it income when received? Should the company amend the prior returns to remove the deducted losses? HOLDING: The $176,271.88 was income on receipt. The prior years correctly reported losses. Amendment of them would be inappropriate. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) FACTS: Company did work for United States during 1913-16. Company had net losses during these years of $176,271.88 In 1916, the company sued the U.S. for the money. In 1920, it collected the $176,271.88 plus interest.1920: ISSUE: How should the company report the recovery? Is it income when received? Should the company amend the prior returns to remove the deducted losses? HOLDING: The $176,271.88 was income on receipt. The prior years correctly reported losses. Amendment of them would be inappropriate. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) FACTS: Company did work for United States during 1913-16. Company had net losses during these years of $176,271.88 In 1916, the company sued the U.S. for the money. In 1920, it collected the $176,271.88 plus interest.1920: ISSUE: How should the company report the recovery? Is it income when received? Should the company amend the prior returns to remove the deducted losses? HOLDING: The $176,271.88 was income on receipt. The prior years correctly reported losses. Amendment of them would be inappropriate. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) FACTS: Company did work for United States during 1913-16. Company had net losses during these years of $176,271.88 In 1916, the company sued the U.S. for the money. In 1920, it collected the $176,271.88 plus interest.1920: ISSUE: How should the company report the recovery? Is it income when received? Should the company amend the prior returns to remove the deducted losses? HOLDING: The $176,271.88 was income on receipt. The prior years correctly reported losses. Amendment of them would be inappropriate. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) FACTS: Company did work for United States during 1913-16. Company had net losses during these years of $176,271.88 In 1916, the company sued the U.S. for the money. In 1920, it collected the $176,271.88 plus interest.1920: ISSUE: How should the company report the recovery? Is it income when received? Should the company amend the prior returns to remove the deducted losses? HOLDING: The $176,271.88 was income on receipt. The prior years correctly reported losses. Amendment of them would be inappropriate. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) FACTS: Company did work for United States during 1913-16. Company had net losses during these years of $176,271.88 In 1916, the company sued the U.S. for the money. In 1920, it collected the $176,271.88 plus interest.1920: ISSUE: How should the company report the recovery? Is it income when received? Should the company amend the prior returns to remove the deducted losses? HOLDING: The $176,271.88 was income on receipt. The prior years correctly reported losses. Amendment of them would be inappropriate. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) FACTS: Company did work for United States during 1913-16. Company had net losses during these years of $176,271.88 In 1916, the company sued the U.S. for the money. In 1920, it collected the $176,271.88 plus interest.1920: ISSUE: How should the company report the recovery? Is it income when received? Should the company amend the prior returns to remove the deducted losses? HOLDING: The $176,271.88 was income on receipt. The prior years correctly reported losses. Amendment of them would be inappropriate. The appellate court permitted exclusion of the recovery in 1920. But, it conditioned this opinion on the taxpayer amending the returns for 1913-16 to omit the prior expenses. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) FACTS: Company did work for United States during 1913-16. Company had net losses during these years of $176,271.88 In 1916, the company sued the U.S. for the money. In 1920, it collected the $176,271.88 plus interest.1920: ISSUE: How should the company report the recovery? Is it income when received? Should the company amend the prior returns to remove the deducted losses? HOLDING: The $176,271.88 was income on receipt. The prior years correctly reported losses. Amendment of them would be inappropriate. The appellate court permitted exclusion of the recovery in 1920. But, it conditioned this opinion on the taxpayer amending the returns for 1913-16 to omit the prior expenses. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) FACTS: Company did work for United States during 1913-16. Company had net losses during these years of $176,271.88 In 1916, the company sued the U.S. for the money. In 1920, it collected the $176,271.88 plus interest.1920: ISSUE: How should the company report the recovery? Is it income when received? Should the company amend the prior returns to remove the deducted losses? HOLDING: The $176,271.88 was income on receipt. The prior years correctly reported losses. Amendment of them would be inappropriate. But, the Supreme Court reversed the appellate court. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) FACTS: Company did work for United States during 1913-16. Company had net losses during these years of $176,271.88 In 1916, the company sued the U.S. for the money. In 1920, it collected the $176,271.88 plus interest.1920: ISSUE: How should the company report the recovery? Is it income when received? Should the company amend the prior returns to remove the deducted losses? HOLDING: The $176,271.88 was income on receipt. The prior years correctly reported losses. Amendment of them would be inappropriate. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) FACTS: Company did work for United States during 1913-16. Company had net losses during these years of $176,271.88 In 1916, the company sued the U.S. for the money. In 1920, it collected the $176,271.88 plus interest.1920: ISSUE: How should the company report the recovery? Is it income when received? Should the company amend the prior returns to remove the deducted losses? HOLDING: The $176,271.88 was income on receipt. The prior years correctly reported losses. Amendment of them would be inappropriate. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) FACTS: Company did work for United States during 1913-16. Company had net losses during these years of $176,271.88 In 1916, the company sued the U.S. for the money. In 1920, it collected the $176,271.88 plus interest.1920: ISSUE: How should the company report the recovery? Is it income when received? Should the company amend the prior returns to remove the deducted losses? HOLDING: The $176,271.88 was income on receipt. The prior years correctly reported losses. Amendment of them would be inappropriate. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) To Repeat: The Supreme Court required inclusion of the recovery in 1920 - the year of receipt. Using an amended return to correct the problem violated the annual accounting system adopted by Congress. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) To Repeat: The Supreme Court required inclusion of the recovery in 1920 - the year of receipt. Using an amended return to correct the problem violated the annual accounting system adopted by Congress. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) To Repeat: The Supreme Court required inclusion of the recovery in 1920 - the year of receipt. Using an amended return to correct the problem violated the annual accounting system adopted by Congress. Congress adopted an annual system, rather than a transactional system. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) To Repeat: The Supreme Court required inclusion of the recovery in 1920 - the year of receipt. Using an amended return to correct the problem violated the annual accounting system adopted by Congress. Congress adopted an annual system, rather than a transactional system. A transactional system could be Constitutional; however, that is not what Congress chose. It also would be cumbersome . . . requiring returns for every transaction!!! © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) To Repeat: The Supreme Court required inclusion of the recovery in 1920 - the year of receipt. Using an amended return to correct the problem violated the annual accounting system adopted by Congress. Congress adopted an annual system, rather than a transactional system. A transactional system could be Constitutional; however, that is not what Congress chose. It also would be cumbersome . . . requiring returns for every transaction!!! © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) To summarize: When you hear of Sanford & Brooks you should associate the case with the general rule that ould also associate the case with transactional accounting and the notion that every year stands alone. Ideally, you would also associate the case with Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) U.S. v. Lewis, 340 U.S. 590 (1951). © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) To summarize: When you hear of Sanford & Brooks you should associate the case with the general rule that ould also associate the case with transactional accounting and the notion that every year stands alone. Ideally, you would also associate the case with Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) U.S. v. Lewis, 340 U.S. 590 (1951). © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) To summarize: When you hear of Sanford & Brooks you should associate the case with the general rule that ould also associate the case with transactional accounting and the notion that every year stands alone. Ideally, you would also associate the case with Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) U.S. v. Lewis, 340 U.S. 590 (1951). Every year stands alone. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) To summarize: When you hear of Sanford & Brooks you should associate the case with the general rule that ould also associate the case with transactional accounting and the notion that every year stands alone. Ideally, you would also associate the case with Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) U.S. v. Lewis, 340 U.S. 590 (1951). Every year stands alone. Another way of saying this is that the United States uses annual rather than transactional accounting. © Steven J. Willis 2006

Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) To summarize: When you hear of Sanford & Brooks you should associate the case with the general rule that ould also associate the case with transactional accounting and the notion that every year stands alone. Ideally, you would also associate the case with Burnet v. Sanford & Brooks, 282 U.S. 359 (1931) U.S. v. Lewis, 340 U.S. 590 (1951). Every year stands alone. Ideally, you should also associate the case with North American Oil v. Burnet, 286 U.S. 417 (1932) and U.S. v. Lewis, 340 U.S. 590 (1951). © Steven J. Willis 2006