FOREWORD HE purpose of the American Federal Tax Reports is to provide a compilation of the cases dealing with the interpretation of Federal Tax Laws, except those arising under the Prohibition and Narcotic Acts. These volumes contain the unabridged opinions in Federal tax cases. They are more than digests, though the purpose for which digests are used is served by the headnotes. The great volume of litigation which has followed the adoption of the Income Tax Laws under the Sixteenth Amendment has created an insistent demand from lawyers and tax consultants for a definitive and unabridged compilation of court decisions interpreting the various Federal Tax Laws. Indeed, the present undertaking was first suggested to the publishers by a government official. For the first time there is made available to those interested in Federal taxes a convenient collection of the court decisions bearing upon this important branch of law. The size of these volumes and the number of cases they contain bear testimony to the fact that the compilation is now quite indispensable. Litigation in respect to disputed questions arising under the Internal Revenue Acts has shown a progressive. increase during the past few years. This increase has been due chiefly to the fact that the later Revenue Acts-particularly those imposing the income and the excess profits taxes-have been exceedingly difficult to interpret and to apply. For those on whom the burden of interpretation falls, whether they represent the taxpayer or the government, every flicker of judicial authority, however remote in time its source, must be of some importance. The principles set forth in decisions under the earlier income and excise tax Acts and included herein still remain, therefore, of great value in the interpretation of the recent laws. In offering this compilation of tax decisions, the publishers have had in mind the following features, all of which will appeal strongly to all persons interested in Federal taxes: 1. The compilation includes an unabridged reprint of the opinions of any importance of every American court-State as well as Federalthat has had before it problems arising under the Federal Tax Laws. Decisions have been included from the date of the earliest acts up to November, 1923. 2. The reprints of Federal decisions-and they, of course, include most of the cases have been made from the original plates of the well-known National Reporter System. The arrangement which makes this accomplishment possible insures absolute accuracy. 3. The headnotes of the National Reporter System are reproduced, and the volumes are therefore usable with the citators and case finders with which lawyers are familiar. 4. The aim has been to include cases bearing on all aspects of the law, including the administrative as well as the substantive sections. 5. The pages are numbered consecutively in this series at the bottom. Top paging refers to volume and page of the court reports from which the respective cases are taken. Thus the user of these Reports can cite, not only this series, but the law reports as well. Summarizing the advantages of these American Federal Tax Reports, we may say that the use of them obviates search for cases scattered through literally thousands of volumes of reported court decisions. The publishers plan to keep the Reports up to date through the periodical issuance of advance sheets. The current interpretation of the Federal Tax Laws through the regulations and rulings of the Treasury Department will be found in the Prentice-Hall Federal Tax Service. PRENTICE-HALL, Inc. 2.M. |