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1927 INCOME TAX PROCEDURE

VOLUME I

DETERMINATION OF NET INCOME AND TAX. PREPARATION OF RETURNS AND PAYMENT.

VOLUME II

PRACTICE BEFORE THE TREASURY, BOARD OF TAX APPEALS, AND FEDERAL COURTS.

INCOME TAX

PROCEDURE

1927

By

ROBERT H. MONTGOMERY, C. P. A.

of Lybrand, Ross Brothers and Montgomery; Counsellor-
at-Law; Former President, American Association of Public
Accountants; Professor of Accounting, Columbia University

VOLUME I

DETERMINATION OF NET INCOME AND TAX.
PREPARATION OF RETURNS AND PAYMENT.

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Copyright, 1927, by

ROBERT H. MONTGOMERY

371862

PREFACE

This edition of Income Tax Procedure is devoted exclusively to the federal income tax. Last year's edition contained a discussion of the taxes on Excess Profits, Estates, Gifts, and Capital Stock. Diminution in interest, and radical changes, in one or the other of these subjects, seemed to justify a postponement at this time of further discussion.

The new 1926 law with its many changes was a problem in itself. A rough estimate indicated that this edition would be in three volumes containing about 4,000 pages, if what might be called interesting material were retained together with the necessary material. The problem became acute. Should I adopt the easy way and retain the rulings, decisions and illustrations dealing with the laws back to 1909, or should my associates and I entirely rewrite the book and eliminate all matter not deemed to be absolutely essential in the year 1927? (Even in tax matters 18 years is no inconsiderable length of time!) We decided to rewrite and to cut ruthlessly, upon the assumption that those who are interested in the latest and the current laws greatly outnumber those who are still engaged in disputes which go back six years or more. It was also assumed that by the use of complete footnote references to previous editions those who are still interested in the old laws can find what they want. The method adopted arose out of a desire to improve the usefulness of the book since experience seems to prove that one volume is superior to two, two volumes tax the patience of readers and three volumes would almost be disastrous.

Much might be said for the 1926 law, but as commendation arises solely out of comparing it with previous unscientific laws, I am under no obligation to divert the attention of taxpayers away from well merited criticism. Enough (perhaps too much) has been said by others regarding the good points of the new law. The major improvement is the reduction in tax rates which has nothing to do with the administrative and substantive provisions which have caused all the trouble in past years. Reference to lower rates obscures questions of far more importance. It is too bad that some of our

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