Obviously the draftsmen of the first Revenue Act under the Sixteenth Amendment could not foresee every possibility of tax avoidance and adequately prevent such avoidance by express statutory provisions. Since the enactment of the Revenue Act of 1913, Congress has made constant efforts in each succeeding Revenue Act to close the loopholes discovered by tax lawyers. The success of these efforts has been most remarkable, particularly in comparison with the similar efforts of England under her income tax laws. Indeed, it may fairly be said that the enactment. of the Gift Tax Act in 1932 wrote the final chapter of the history of serious tax avoidance.
William C. Warren,
THE REDUCTION OF INCOME TAXES THROUGH THE USE OF TRUSTS,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol34/iss6/3