The evolution of today's Internal Revenue Code, which began with the mere embryo that Congress created in 1913, has absorbed over the ensuing sixty-four years more creative energy on the part of more co-authors than any other law in history. Despite this unstinted expenditure of "blood, sweat, and tears," the resulting document--were it possessed of human senses--would recognize that, for a foreseeable period, its life will be anything but serene. The plight in which it would find itself could even be compared to that early morning scene observed one hundred years ago by General Custer, when hostile forces were massed on every front and would shortly be placing his entire command under siege.
L. H. Wright,
Carter's Projected "Zero-Based" Review of the Internal Revenue Code: Is Our Tax Code to be "Born Again"?,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol75/iss5/16