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Federal Income, Estate, and Gift Tax Project records
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Held at: University of Pennsylvania: Biddle Law Library [Contact Us]3460 Chestnut Street, Biddle Law Library, Philadelphia, PA 19104-3406
This is a finding aid. It is a description of archival material held at the University of Pennsylvania: Biddle Law Library. Unless otherwise noted, the materials described below are physically available in their reading room, and not digitally available through the web.
Overview and metadata sections
In the mid-1940s, the American Law Institute (ALI) set about to analyze the law as it related to income tax. Known as the Income Tax Project, the primary objective was not to codify the law but to provide analysis of issues as they related to the United States' increasingly complex tax code. In 1954, the ALI published its first suggestions, known as the February 1954 Draft. The draft was made available to tax specialists and especially Congress, which was considering a major overhaul of the income tax law (which became the Internal Revenue Code in April 1954).
In subsequent years, the ALI analyzed specific aspects of the Internal Revenue code, publishing a suggestive framework for dealing with the problems but never formally adopting any of its findings. These projects included a study of corporate taxation (1956-1958), capital gains taxation (1959-1960), and donative transactions and accessions tax (1961-1968). The groups within ALI that worked on these projects included the Tax Policy Committee (the primary group), special consultants, reporters, and the Tax Advisory Group (which was made up of members from the Tax Policy Committee and tax specialists not necessarily affiliated with the ALI). Unlike its earlier codification projects, the Federal Income, State, and Gift Tax Project (as it would eventually be known) consisted of a series of non-binding recommendations to students, teachers, litigators, and legislators as they dealt with the evolving tax code.
The ALI adjourned the Income Tax Project in 1969. It was revived under different personnel in 1974 in a renewed effort to analyze updates in the tax code.
The Federal Income, Estate, and Gift Tax Project Records, 1946-1981 and undated (bulk: 1949-1969), include correspondence, meeting minutes, drafts, memoranda, comments, outside publications, and related records concerning various tax-related projects conducted by the ALI from the mid-1940s to 1969.
- Administrative Records
- Correspondence
- Meeting Records
- Drafting Records
- Commentary
- Article Reprints
First shipment received from the American Law Institute in 1995.
An item-level container list is available offline in spreadsheet form.
Preliminary container list prepared by Melissa Backes, 1995-2005.
Reprocessed by Jordon Steele, September-November 2007.
Encoded by Jordon Steele, May 2008.
- Publisher
- University of Pennsylvania: Biddle Law Library
- Finding Aid Author
- Jordon Steele
- Finding Aid Date
- 2008
- Use Restrictions
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None.
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The archives reserves the right to restrict access to materials of sensitive nature. Please contact the department for further information.
Collection Inventory
Fundraising solicitations, tax exemption documents, expense reports, correspondencepublications, and other records related to the administrative functions surrounding the Income Tax Project.
General Physical Description noteAbout 50 items
Letters and related records between ALI members, the Tax Advisory Group, and other participants in the ALI's tax projects.
General Physical Description noteAbout 2000 items
Minutes and related records involving ALI members, the Tax Advisory Group, and other participants in the ALI's tax projects.
General Physical Description noteAbout 6000 items
Initial drafts that outline the objectives of the ALI's Income Tax Project.
General Physical Description noteAbout 360 items
Initial drafts that outline the objectives of the ALI's Income Tax Project.
Physical Description4 items
Drafts related to projects involving income tax law, including the February 1954 draft, the corporate tax law study, and the capital gains tax study.
General Physical Description noteAbout 235 items.
25 items
Drafts related to the February 1954 draft and the corporate tax law study.
Physical Description19 items
Memoranda, officially submitted to the ALI, concerning aspects of the Internal Revenue Code involving foreign tax provisions.
Physical Description9 items
The ALI published this two-volume set in February 1954 to advise Congress as it was considering legislation to overhaul the Internal Revenue Code. That legislation passed in April 1954.
Physical Description2 items
Drafts related to a two-year study, conducted from 1956 to 1958, between the ALI and the American Bar Association Section of Taxation Liaison Committee. The project considered issues, first raised in the February 1954 Draft, concerning corporate taxation.
Physical Description4 items
Council drafts and discussion drafts related to a non-binding study by the ALI that explored definitional issues within the field of capital gains taxation.
Physical Description6 items
Memoranda, council drafts, study drafts, and other drafting records related to studies conducted by James A. Casner and William D. Andrews, both Harvard Law School professors, involving gift tax and accession tax provisions in the Internal Revenue Code. The ALI synthesized both reporters' studies and promulgated its own recommendations. However, in the interest of documenting the collaboration between all involved parties, all three drafts were published in one volume.
Physical Description48 items
Drafts, letters, and related records not formally submitted to any committee within the ALI but considered during the drafting process of various tax-related projects.
General Physical Description noteAbout 30 items
Comments, memoranda, and letters from members of the American Law Institute, advisory group members, and other members of the greater tax law community.
General Physical Description noteAbout 100 items
A collection of article reprints, taken from scholarly journals, that discuss the drafting and publication of the American Law Institute's tax-related projects.
Physical Description10 items