Schortmann v. United States

OPINION

ALLEGRA, Judge.

“To every complicated problem there is a simple solution, which turns out to be wrong.”1

Various temporal limitations are interwoven into the Federal income tax system. The warp of that system is the annual accounting principle, famously described in Burnet v. Sanford & Brooks Co., 282 U.S. 359, 365, 51 S.Ct. 150, 75 L.Ed. 383 (1931), which vertically limits the calculation of income to events occurring within a given taxable year. Then, there are the wefts supplied by the limitation provisions in the Internal Revenue Code (26 U.S.C.), which introduce into the weave…