The discussion here has to do with the earnings of corporations as taxable income, whether such earnings remain in the hands of the corporation accumulating them, or are distributed to the stockholders as dividends, the inquiry being limited, however, to the question of the time of their accrual as affecting their taxability.
Robert M. Drysdale & Maurice C. McGiffin,
Corporate Earnings as Gains Profits and Income as Depending Upon the Time of Their Accrual,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol16/iss4/2