Taxation. Federal. Recovery against Collector of Internal Revenue for Overpayment Is Not Res Judicata of Further Claim against the United States

The two revenue-collecting services of the United States government offer interesting contrasts in the methods used for the administrative control of their respective field services. This arises in large part from the fact that the Bureau of Customs has been the more decentralized service. Ever since its establishment in 1789, and in the course of a long and continuous existence, it has built up a background of traditional decentralization which contrasts with the policy of centralization characterizing the Bureau of Internal Revenue. The latter service has a much shorter history, really beginning in 1862, although internal taxes were levied by the federal government from 1791 to 1802, and from 1813 to 1817. By virtue of the fact that Congress conferred administrative powers directly upon the commissioner of internal revenue, rather than upon the Secretary of the Treasury (as was done in the case of the customs service), a more integrated and centralized system of control has been used in the internal revenue service since the beginning of its existence.

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The Res Judicata Effect of Suits against Government Officers in Litigation with the United States

Virginia Law Review ◽

10.2307/1071469 ◽

1965 ◽

Vol 51 (2) ◽

pp. 306

Keyword(s):

United States ◽

The United States ◽

Res Judicata

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The Orinoco Steampship Company Case Before the Hague Tribunal

The American Journal of International Law ◽

10.2307/2186764 ◽

1911 ◽

Vol 5 (1) ◽

pp. 35-64 ◽

Cited By ~ 1

Author(s):

William Cullen Dennis

Keyword(s):

United States ◽

The United States ◽

Arbitral Tribunal ◽

International Arbitration ◽

Res Judicata ◽

The Future ◽

The Hague

On the 9th of April, 1911, the Hague court will celebrate its first decennial. The first decade of the court was opened by the submission on the part of the United States and Mexico of the Pious Fund case to the tribunal for its decision, and of the eight cases so far submitted to the court and brought to trial during the first decade, the United States has been a party in four, and in a fifth, the Japanese House Tax case, the United States agreed to abide by the result. The last case to be tried was the Orinoco Steamship Company case submitted by the United States and Venezuela.Both the Pious Fund and the Orinoco Steamship Company case raised important questions vitally affecting the future of international arbitration. Both cases were peculiar in that they dealt with a question which had already been once before decided by an arbitral tribunal. In both cases the effect of the previous arbitral decision was submitted as a preliminary question to the Hague court. In the Pious Fund case the preliminary question submitted was as to whether the claim, as a consequence of the former decision of Sir Edward Thornton, umpire under the convention between the United States and Mexico of 1868, was within the principle of res judicata. The court sustained the contention of the United States, by holding that the rule of res judicata applies to international arbitral sentences “ rendered within the limits of the jurisdiction fixed by the compromise,” and accordingly rendered judgment in favor of the United States, without considering the merits of the claim.

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The United States Internal Revenue Tax System

Harvard Law Review ◽

10.2307/1322149 ◽

1895 ◽

Vol 9 (2) ◽

pp. 167

Author(s):

A. K. G. ◽

Charles Wesley Eldridge

Keyword(s):

United States ◽

The United States ◽

Tax System ◽

Internal Revenue

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THE EVOLUTION OF ACCOUNTING FOR CORPORATE TREASURY STOCK IN THE UNITED STATES

Accounting Historians Journal ◽

10.2308/0148-4184.5.1.1 ◽

1978 ◽

Vol 5 (1) ◽

pp. 1-7

Author(s):

Norlin G. Rueschhoff

Keyword(s):

United States ◽

The United States ◽

Internal Revenue ◽

Net Equity ◽

The Many

Is treasury stock an asset or a reduction of net equity? This study is concerned with the process of accounting for treasury stock from as early as 1720 to date. It illustrates the many methods which have been used to create funds by the purchase and sale of treasury stocks and concludes with a consideration of the effects of the Internal Revenue Act of 1934 and the Security Exchange Act of 1934 on the treatment of treasury stock.

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