Robert C. Elmore
UNIVERSITY OF ALABAMA — HUNTSVILLE
THE INFLUENCE OF TAX LEGISLATION ON FINANCIAL ACCOUNTING: A STUDY OF THE TIMBER INDUSTRY, 1905-1925
Abstract: The purpose of this paper is to examine the financial accounting records of a Mississippi timber company and its sub-sidiaries in light of the dynamic tax environment of the period 1905 to 1925. The financial accounting records and correspondence with the Commissioner of Internal Revenue indicate deficiencies in the following areas: asset valuation, a lack of a cost accounting system to adequately value inventories, and the depletion and depreciation deduction. The demands of the new tax laws were often in conflict with the accounting practices of this period of time forcing changes in accounting practice.
Introduction
The accounting practices of individual corporations are shaped by their dynamic relationships with regulatory and environmental conditions. The conflict between accounting practices and regulations should be studied” … in terms of changes-rather than its static order”[Saito, Spring 1983, p. 2]. An example of a conflict between practices and regulations existed between accounting practices and the newly enacted tax laws at the beginning of the twentieth century. No other period of time has experienced the sweeping changes in the tax environment as did the years of 1905 to 1925, with the enactment of the Corporation Excise Tax of 1909, and the Revenue Acts of 1913, 1918, 1921, and 1924. The requirements of these new tax laws often conflicted with the existing accounting practices in the areas of inventory valuation, depletion, asset valuation, and depreciation. Prior to the enactment of these tax laws, corporations faced few constraints from any type of governmental regulation. The purpose of this paper is to examine the financial records of a Mississippi timber company, the L. N. Dantzler Company, and its subsidiaries, and the influence of this dynamic tax environment on their financial accounting principles and cost accounting systems.
Methodology
The practice of accounting has often been influenced by tax legislation. An examination of the financial statements, jour-nals, and correspondence with the Commissioner of Internal Revenue of the L. N. Dantzler Co. provides evidence of changes made in the accounting system in order to comply with tax legislation. In addition, a 1917 tax protest provides an explanation of the accounting methods used and the motivation for various changes made in the accounting system. Court cases indicate that Dantzler’s tax and accounting problems were common to the timber industry at the beginning of this century. Contemporary tax guides and journal articles are used to explain accounting practices in the timber industry during this period.
Background
The timber industry is the oldest industry in the United States, beginning on the east coast and gradually moving west as new timber supplies were needed. Timber production reached its peak in the South in 1909. From 1870 to 1920 an estimated 511,000,000,000 board feet of timber, four-fifths of the original timber, was cut [Smith, August 1933, p. 221]. During this period of high production, the Southern timber industry, with many small companies, was characterized as highly competitive. The tremendous growth began to slow in the 1920’s, and by 1930 the Southern timber industry was in decline [Pixton, Dec. 1932, p. 448]. Therefore, during the implementation of these new tax laws the timber industry was a very important part of the economy of the Southeast and of Mississippi.
The L. N. Dantzler Lumber Company, with outstanding capital assets of $200,000, was incorporated in 1888 as one of the first chartered private corporations in the state of Missis-sippi. By 1900 Dantzler was producing over 90,000,000 board feet of lumber annually, being one of the three large timber companies in the Moss Point, Mississippi area. During the period of time examined by this paper, Dantzler purchased numerous small timber companies in the Moss Point-Pascagoula area. The financial records of several of these small companies are available for the period prior to their purchase by Dantzler. Later, the Dantzler Company expanded their timber operations into Nicaragua, Prince Edward Island, Oregon, and Georgia. Dantzler also had export businesses in New Orleans and Tampa, and a distribution business involving twenty barges and tugs, 200 miles of railroads with 24 steam locomotives, and 300 log cars. Other business interests included shipbuilding, foundry and machine shops, and plantations in the Mississippi Delta. Operations were suspended in 1938 because of the depression: however, World War II resulted in operations being restarted. The company ceased all manufacturing and logging operations in 1949.
Corporation Excise Tax of 1909
The first important tax legislation enacted during the period 1905-1925 was the Corporation Excise Tax of 1909. This tax was not a direct tax and “was not intended to be and is not in any proper sense an income tax law,” but an excise tax “measuring the amount of tax by the income of the corporation with certain qualifications perscribed by the Act itself” [Strat-ton’s Independence v. Howbart, 231 U.S. 399]. Therefore, this excise tax was considered constitutional prior to the passage of the sixteenth Amendment. A deduction was allowed for depreciation, but no mention was made of the allowability of a depletion deduction. This resulted in attempts by various companies engaged in the production of natural resources to have depletion deducted as depreciation. The Commissioner of the Bureau of Internal Revenue disagreed. Eventually this disagreement culminated in several court cases. The courts disallowed the depletion deduction in mining companies, but allowed it in the timber industry. In Stratton’s Independence vs. Howbart [231 U.S. 399], an important lawsuit involving a mining company, the plaintiffs contended that the mining of ore is the reduction of an ore deposit which would be depreciation of a capital asset and therefore deductible. The Supreme Court ruled that allowance of a depletion deduction for mining companies would exclude them from the tax the manufacturers had to pay, therefore denying the depletion deduction. A later court decision, Doyle vs. Mitchell Brothers Company [247 U.S. 179], decided in 1918, but under Section 38 of the Corpo-ration Excise Tax of 1909, accepted the depletion deduction for timber companies based upon the market value of the timber at the time of the act.
The Court concluded in this case that “in order to determine whether there has been gain or loss, and the amount of gain if any, we must withdraw from gross proceeds an amount sufficient to restore the capital value that existed at the commencement of the period under consideration.” This Court decision established that the return of capital is not income, therefore allowing the depletion deduction. By the time this decision was made, later tax laws had already established the appropriateness of a deduction for timber depletion. There are several possible reasons why depletion was deductable for timber, but no ore deposits under this 1909 Act. First, and most obvious is that timber is easier to estimate because it is above the ground. Secondly, the courts were not willing to allow the mining companies to avoid the Act by deducting the entire difference between net income and gross receipts as the original cost of the ore, and therefore a return of capital [McGill, 1936, p. 305].
The Effect of the 1909 Excise Tax on the Timber Companies
The financial records of three Mississippi timber companies are available for the periods before and after the im-plementation of the 1909 Act. The 1909 Excise Act had a different effect upon the accounting reporting practices of each of these three companies. The first company providing financial records is the Ten Mile Lumber Company of Ten Mile, Mississippi. This was a very small company that was later purchased by Dantzler. Financial statements prepared regularly preceeding and subsequent to this act include a Statement of Assets and Liabilities, and Statements of Sales, Purchases, and Timber Costs. The statements were all prepared on a cash basis. Costs and revenues are only matched when each shipment is made. The emphasis on the balance sheet and ownership interests is evident, as would be expected during the period prior to the emphasis on income required by the tax laws. Furthermore, there is no deduction of depletion or depreciation. The financial records of the Ten Mile Lumber Company showed no response to the enactment of the Excise Tax of 1909.
Financial statements for the Native Lumber Company of Howison, Mississippi are also provided during the implementa-tion of the 1909 Excise Act. Included in these financial state-ments are Cost Statements, a Statement of Lumber Sales, a Realization Schedule, and a Reconciliation of Profit and Loss. The 1911 Realization Schedule is presented in Exhibit 1. A change in emphasis that is evident was from income by order or shipment to income for the company as a whole. Also an adjustment was made for lower of cost or market valuation of inventory. The Reconciliation of Profit and Loss and the Realization Schedule also indicate that depreciation was deducted, but depletion was not deducted.
Exhibit 1
The third company examined for this period of time is the . N. Dantzler Lumber Company. The Cost Statements, Lumber Sales Statements, a Realization Schedule, and Recon-ciliation of Profit and Loss are the financial statements provided. The 1912 Realization Schedule is presented in Exhibit 2, sheets 1 and 2. Reconciliation of Profit and Loss indicates a matching of revenues and expense for the entire company and deductions for both depreciation and depletion
Exhibit 2 Sheet 1
Why was there a difference in the reaction to the 1909 Excise Act by three timber companies operating in the same geographical area? Perhaps the most significant difference is in the preparers of the financial statements and the tax records. The Ten Mile Lumber Company, prior to becoming a subsidiary of Dantzler, provided statements emphasizing the balance sheet, with no “Realization Schedule”. The lack of a “Realization Schedule”, providing a matching of revenues and losses for the entire company, and the emphasis on profitability by order shipped, indicates a continuation of the same accounting practices prior to the enactment of the 1909 Act. On the other hand, Native Lumber Company emphasized profit and loss for the company as a whole, and used the depreciation deduction, indicating an awareness of the change in the law. The lact of a depletion deduction is understandable at this time due to the uncertainty of its deductibility because of the time lapse between the implementation of the act and the court decision allowing the depletion deduction. Both of these com-panies used local accountants. Finally, Dantzler prepared a Realization Schedule taking both the depreciation deduction and the depletion deduction. Their correspondence with the Bureau of Internal Revenue indicates that they retained a Washington, D.C. law firm to compute their taxes. Seemingly, compliance with the new tax law depended to some extent upon the ability to hire a tax practitioner that understood it.
The Revenue Act of 1913
The Sixteenth Amendment was ratified on February 25, 1913, and on March 1, 1913, the first income tax law went into effect. The Act provided for “a reasonable allowance for the exhaustion, wear, and tear of property arising out of its use or employment in the business” [Revenue Act of 1913, Section II, G]. In Stanton v. Baltic Mining Co. [240 U.S. 130] the courts determined that Congress had the statutory power under the Sixteenth Amendment to either allow or not allow deductions for depreciation and depletion. Such a deduction was not “a matter of right,” but if any such deduction is taken” . . . authority must be found in the statute” [Burnet v. Thompson Oil Co. 283 U.S. 301].
Complete financial statements for the L. N. Dantzler Lumber Company, the Ten Mile Lumber Company of Ten Mile, Mississippi, and the Native Lumber Company of Howiston, Mississippi are available for 1911-1913. By the time of the enactment of the 1913 Revenue Act, all three companies were deducting depreciation and depletion. Also, all the companies were preparing some type of realization schedule on the accrual basis, matching revenues and expenses for the fiscal year. The 1913 Realization Schedule for L. N. Dantzler is presented in Exhibit 3, sheets 1 and 2.
Exhibit 3 Sheet 2
Exhibit 3 Sheet 1
Correspondence with the Commissioner and the tax protest for the 1917 calendar year provide insight as to how the various amounts on the financial statements were computed, and changes that were made in order to comply with the new tax laws. The correspondence and the protest mention several areas of deficiency in the financial accounting system that created tax problems. First, records of timber valuation and of timber cuttings were often not accurate. The cost depletion method required in the timber industry was based upon accurate records of timber cuttings. Records did not indicate where the timber was cut, only where it was shipped. These records were extremely important because they were the basis for depletion and the units of production method of depreciation. Second, assets were recorded at cost, with little attention paid to subsequent use or disposition. Since depreciation was not always deducted prior to 1913, records beyond the initial purchase of the assets were not always maintained. Assets from one company were often intermingled with assets from other companies as the need for them would arise. Finally, there was no separate cost accounting system. Timber cuttings were very much estimates. Only a financial accounting system existed which also provided records for tax purposes. Therefore, tax laws had a direct effect upon the financial accounting system. Each of these financial accounting deficiencies are discussed in the following sections.
Timber Valuation and Depletion
As mentioned previously, deductions for timber depletion had been allowed since 1909. During the period 1909-1918 the Treasury Department issued rulings allowing a depletion de-duction from gross receipts, or a charge against the cost of manufacturing the timber into lumber [Holmes, 1922, p. 767]. These rulings were eventually written into the statutes allowing for timber as well as other natural resources “a reasonable allowance for depletion and for depreciation of improvements, according to the peculiar conditions in each case, based upon cost, including cost of development not otherwise deducted. Provided, that in the case of such properties acquired prior to March 1, 1913 the fair market value of the property on that date shall be taken in lieu of cost up to that date” [Internal Revenue Act of 1918, Section 234 (a) (9)].
The requirement by the federal tax acts that the timber acquired prior to March 1, 1913, be accounted for at the fair market value of the timber at that date caused complications for the timber companies. Timber had to be revalued, and had to be accounted for separately from the timber acquired sub-sequent to this date. Timber was acquired in three ways: purchase of timber land, purchase of timber rights, or purchase of logs. This provided records of the original cost. Depletion was determined by first estimating the amount and quality of standing timber and then estimating the average cost of all the stumpage owned. This average cost of stumpage owned was then multiplied by the number of board feet cut to determine the depletion. Estimates of standing timber were made by “professional timber cruisers” who were, according to Wyler, “more or less trustworth” [June 1923, p. 108]. However, Smith [Aug. 1933, p. 202] points out that the material records, with the exception of lumber shipped, were “. . .more apt to be incorrect than correct.” An incorrect estimate could cause the accountant the embarrassment of having timber on the books and none in the woods if these timber estimates were not conservative [Smith, August 1933, p. 202]. Generally the amount cut was determined at the point that the lumber was loaded for shipment.
Inventories were based upon the following:
Logs cut @ sawmill log scale
+overruns
+ending inventories
-Lumber shipped
= Lumber inventory at the end of the period
This computation caused few problems because of the ease of determing the amount of timber cut, but the estimate of the total amount of timber available was difficult to compute, and served as a basis for subsequent depletion charges. Wyler [June 1922, p. 108] indicated that “In the past many lumber man-ufacturers have used an arbitrary rate for depletion, which was not based directly upon the cost of timber.” Furthermore, the very prosperous mills would use as a basis the market value of the finished product. These market rates would fluctuate making their use difficult. Only the smaller mills used actual cost. As if the accountant did not have enough problems, the average depletion unit would usually change from year to year because of additional purchases.
Inventory Records
The L. N. Dantzler Lumber Company was also experienc-ing problems with the estimates used as a basis for valuation of the standing timber for depletion purposes and the lack of accurate records of subsequent timber cuttings. In the formal tax protest, Dantzler admitted their financial accounting re-porting weaknesses to the Commissioner of the Bureau of Internal Revenue. Their tax advisor stated that the “Dantzler Lumber Company, as did a majority of other companies prior to the year 1917, paid comparatively little attention to depletion, and therefore whatever amounts were taken as depletion, up to 1917, do not represent the results of any careful analysis of either cost or March 1, 1913 value, but were rather rough estimates.” Dantzler’s tax advisor also admitted the March 1, 1913 valuation used as a basis for depletion and depreciation was a “rank guess” and was not figured accurately until the “later part of 1919.” Depletion was a “rough estimate” at best. Due to the newness of the tax laws, there seemed to be little comprehension of requirements for compliance in the accounting records.
Court Cases on Depletion Under The 1913 Act
Dantzler Lumber Company’s problems were not unique. An examination of the court cases of the time shows that lack of accurate records was common to the entire timber industry. The difficulties were created by the requirement that the March 1, 1913 market value became the basis for depletion deductions on timber purchased prior to the enactment of the Revenue Act of 1913, and also the basis for unit of production depreciation. The Commissioner would contest the market value attempting to reduce it thereby reducing subsequent depletion and depreciation deductions. Generally, the courts held that the burden of proof was on the taxpayer to show “competent evidence” that the Commissioner’s valuation and subsequent depletion deductions were incorrect [Nickey and Sons v. Commissioner, 3 BTA 173]. Accountants of this time complained that depletion was used to manipulate profit. The deduction would either be based on the fair market value of the finished product or the fair market value prior to cutting depending on whether the company wanted to show a profit or a loss [Wyler, June 1922, p. 107]. After the enactment of the income tax, the Commissioner tried to discourage this type of manipulation. Although the arguments for valuation are of little interest today, several factors involving financial accounting reporting are involved.
First, a reading of the various court cases supports the impression that separate cost accounting records of timber valuation and of subsequent cuttings were generally not main-tained. The timber companies were often forced to recapitulate their records at a future date working “back to stumpage.
Secondly, the courts seemed somewhat confused by the entire valuation and subsequent depletion process. Generally the testimony of expert witnesses weighed heavily upon the decision [W. M. Ritter Lumber Co. v. Commissioner, 30 BTA 231]. This was especially true if they were impartial. Compromises were often accepted [Houston Bros. v. Commissioner, 22 BTA 51]. Perhaps, the lack of expertise of the judges in timber valuation had an effect upon the willingness of the judges to compromise despite the fact that the Regulations allowed only changes for fraud, misrepresentation, or gross error [Benson Lumber Co. v. Commissioner, 9 BTA 593; Boyne City Lumber Co. v. Doyle, 47 F2d 772].
Thirdly, there seemed in some cases to be little comprehension by the timber companies that they would actually have to maintain accurate records for documentation of valuation basis for depletion and depreciation [A. B. Nickey & Sons v. Commissioner, 3 BTA 173]. This review of court cases indicates that difficulty in compliance with the new income tax law was not just a problem for Dantzler. Compliance with the new tax law was also difficult for other companies in the timber industry.
Asset Valuation and Depreciation
Depreciation of assets in the timber industry was usually based upon the exhaustion of the available timber, using the same basis as depletion. The depreciable value was divided by the available timber supply resulting in a timber rate that was multiplied by the saw mill cut in order to determine the annual depreciation. This units of production depreciation was accepted for timber companies by the courts. For example, the Court in Bacon-McMillan v. Commissioner [20 BTA 556] allowed a “. . .reasonable deduction on account of the exhaustion, wear and tear of the physical property . . . that . . . should be allowed as would return to the taxpayer the cost or March 1, 1913 value.” The physical assets would be exhausted when “the timber or other resources in connection with which it is used “…have become exhausted.” Straight-line depreciation was only used when there was a perpetual cut, which was generally not done at this time. Therefore, depreciation had the same valuation problems as depletion. Depreciation also had to be adjusted each year based upon additional timber acquired. The plant was reduced to salvage value when the timber was exhausted [Wyler, June 1922, p. 107].
Dantzler’s depreciation was not always recorded. When small timber companies were purchased, their assets were intermingled and moved as they were needed on other tracts. Often the source of the timber cuttings was ignored, making use of the units of production method very difficult. Furthermore, the auditors did not seem to understand, or perhaps did not want to become involved in the computation of depreciation. For example, a Savannah, Georgia auditor stated in Dantzler’s annual audit report that, “I did not enter depreciation this time. Considerable repairs have been made in your property, and I consider that the plant has appreciated.”
Separage Cost Accounting Systems
As late as the 1930’s, accountants were still critical of the financial accounting records maintained by the timber com-panies. A common criticism was that very often a cost accounting system was not maintained separately from the fi-nancial records. Even in the most sophisticated systems, Smith [Aug. 1933, p. 221] pointed out that the only cost accounting records maintained were the “timber cruiser’s estimate of standing timber, log scale in the woods, saw-mill log scale, board measure of lumber shipped, and . . . the periodical log and lumber inventories.” Smith further complained that material records and costs had not received the study and attention that they deserved. An accurate cost accounting system maintained at the mill would have provided documentation of the timber cuttings.
Although the L. N. Dantzler Company did admit the lack of a cost accounting system in their tax protest, they did prepare a separate cost statement for logging, which became part of the financial accounting system. This format of this cost statement was as follows:
Total Cash Costs for Logging
+ Stump age
+Addition Expenses (General and Administrative)
+ Purchases of Timber
+ Beginning Inventory
-Ending Inventory
= Costs
This logging cost was matched against sales in a Sales Statement, and then carried on the Realization Schedule and the Reconciliation of Profit and Loss.
Subsequent Revenue Acts
The 1921 Revenue Act also required the use of March 1, 1913 market valuation “in lieu of cost” as a basis for depletion [Internal Revenue Act of 1921, Section 234 (a) (9)]. However, the 1924 Act made a significant change in the computation of depletion. The basis “… upon which depletion, exhaustion, wear and tear, and obsolescence are to be allowed shall be the same as provided . . . for the purpose of determining the gain or loss upon the sale or other disposition of such property. The basis used for property acquired before March 1, 1913 will be the cost or the fair market value ‘whichever is greater’ ” [Internal Revenue Act of 1924, Section 204 (b) and Section 204 (c)]. The Finance Committee and the Ways and Means Committee of Congress pointed out that this “… changes the existing law in the interest of the taxpayer and that it simplifies exceedingly the rule and effect under the present law without appreciable loss to the Treasury [Holmes, 1925, p. 637].
The 1917 Tax Protest of Dantzler
The Washington, D. C. law firm prepared numerous docu-ments to support Dantzler’s position in their hearing with the Commissioner. This included the establishment of a 1921 valu-ation and a “back to stumpage” recapitulation of the financial statements. The amount of tax disputed for 1917 was $6,835.28. An expense of $1,999.61 for “U.S. Government Suit and Cost” also appears on one of the Reconciliations of Profit and Loss. Considering the fact that Dantzler’s Realization Schedules for the years prior to this protest indicate a net income for each year of $300,000 to $400,000, the $6,835.28 seems rather immaterial. However, Wyler [June 1922, p. 106] in a Journal of Accountancy article refers to 1917-1921 as the “high tax period”. Therefore, the taxes may not have been high based upon current tax laws, but they were considered high by Dantzler’s contemporaries.
Also prior to World War I, most of Dantzler’s timber was being shipped to foreign markets. The Reconciliation of Profit and Loss for 1917 shows an net loss of $8,268.59, expressing financial difficulties caused by shipping problems created by World War I. Furthermore, a footnote to the 1917 financial statements indicates that Dantzler only operated part of 1917 because of the problems created by the war. Therefore, the war created a rapid change in Dantzler’s financial condition.
Conclusion
This paper has summarized the changes in the tax laws faced by several Mississippi timber companies during the period 1905-1925. This period of time saw an uncertain and rapidly changing tax environment not experienced at any other time in our history. These changes in the tax environment also forced changes in the financial accounting systems because of the lack of other authoritative bodies to establish accounting practices. Exhibit 4 presents the observed changes in the financial statements in response to each new tax legislation. The 1917 tax protest indicated the influence of the tax laws upon the following areas of financial and cost accounting of the L. N. Dantzler Co.:
(1) Changes in the emphasis from the balance sheet and ownership interests to the income statement and income determination;
(2) Acceptance of the depreciation and depletion deduction;
(3) Improvements in accounting for assets;
(4) Improved recordkeeping for inventories.
The lack of separate cost accounting systems and the in-adequacies of inventory valuation created difficulties in asset valuations and subsequent depreciation and depletion charges. This caused the resulting net income figures that were used for income tax purposes to very often be questioned when existing financial accounting systems could not provide the appropriate documentation to the satisfaction of the Bureau of Internal Revenue. Problems of estimation were not crucial until reliance upon them for tax purposes. Furthermore, these were the first dealings these companies had with a federal tax system. Therefore, companies, such as Dantzler, found difficulty in knowing how to deal with the tax situation due to this lack of prior experience.
56
The Accounting Historians Journal, Fall, 1987
EXHIBIT 4
SUMMARY OF SIGNIFICANT TAX LEGISLATION AND THE EFFECT UPON THE MISSISSIPPI TIMBER COMPANIES
FINANCIAL STATEMENTS PRIOR TO THE CORPORATION EXCISE TAX OF 1909:
TAX ACT:
Corporation Excise Tax of 1909
Revenue Act of 1913
Revenue Act of 1924
Balance Sheet
Cash Basis Shipping Reports Matching of Revenues and Expenses by Shipment.
CHANGES IN FINANCIAL STATEMENTS AFTER THE ACT:
Ten Mile Lumber Co.: No change
Native Lumber Co.: Addition of Accrual Bases Realization Schedule Deduction of Depreciation
L. N. Dantzler Co.: Addition of Accrual Basis Realization Schedule Deduction of Depreciation Deduction of Depletion
Ten Mile Lumber Co.: Addition of Accrual Basis Realization Schedule Deduction of Depreciation Deduction of Depletion
Native Lumber Co.: Deduction of Depletion
L. N. Dantzler Co.: Protest of 1917 Taxes under the
1913 Act Change from March 1, 1913 fair market value as a basis for deple-tion and depreciation to greater of fair market value or cost.
REFERENCES
Bacon-McMillan Veneer Co. v. Commissioner, 20 BTA 556 (1923).
Benson Lumber Co. v. Commissioner, 9 BTA 593 (1931).
Boyne City Lumber Company v. Doyle, 47 F2d 772, 9 AFTR 1015, (1930).
Burnet v. Thompson Oil Company, 283 U.S. 301, 51 SCt 418, 9 AFTR 1434 (1931).
Dantzler Lumber Company, Collected Papers, Archives, University of Mississippi.
Doyle v. Mitchell Brothers Company, 247 U.S. 179, 38 SCt 467, 3 AFTR 2979 (1918).
Heineman Lumber Co. v. Commissioner, 11 BTA 1229 (1931).
Holmes, G. E., Federal Income Tax, Indianapolis: Bobbs-Merrill Co., 1925.
Houston Brothers v. Commissioner, 22 BTA 51 (1931).
McGill, R., Taxable Income, New York: Ronald Press, 1936.
Nickey & Sons v. Commissioner, 3 BTA 173 (1931).
Pixton, M. F., “Some Economic and Accounting Phases of Lumber Accounting,” The Journal of Accountancy, (December 1932), pp. 445-455.
Ritter Lumber Co. v. Commissioner, 30 BTA 231 (1939).
Rust-Owen Lumber Co. v. Commissioner, 742d 18, 14 AFTR 796 (1934).
Saito, S., “Asset Revaluation and Cost Basis: Capital Evaluation in Corporate Financial Reports,” The Accounting Historians Journal, (Spring 1983), pp. 1-23.
Smith, R. W., “Lumber Accounting,” The Journal of Accountancy, (August 1933), pp .200-201.
Stanton v. Baltic Mining Co., 240 U.S. 103, 36 SCt 278, 3 AFTR 2939 (1916).
Stratton’s Independence v. Howbart, 231 U.S. 399, 34 SCt 136, 3 AFTR 2883 (1913).
Wyler, R. S., “Special Phases of Lumber Accounting,” The Journal of Accountancy, (June 1922), pp.107-112.
