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Federal Income, Estate, and Gift Tax Project records


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.

  1. Administrative Records
  2. Correspondence
  3. Meeting Records
  4. Drafting Records
  5. Commentary
  6. 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.

University of Pennsylvania: Biddle Law Library
Finding Aid Author
Jordon Steele
Finding Aid Date
Use Restrictions


The archives reserves the right to restrict access to materials of sensitive nature. Please contact the department for further information.

Collection Inventory

Administrative Records, 1948-1981. About 50 items.
Box 17 Folder 31 Box 1 Folder 1-3
Scope and Contents note

Fundraising solicitations, tax exemption documents, expense reports, correspondencepublications, and other records related to the administrative functions surrounding the Income Tax Project.

General Physical Description note

About 50 items

Correspondence, 1947-1969. About 2000 items.
Box 2 Folder 1-15 Box 1 Folder 4-51
Scope and Contents note

Letters and related records between ALI members, the Tax Advisory Group, and other participants in the ALI's tax projects.

General Physical Description note

About 2000 items

Meeting Records, 1948-1969. About 6000 items.
Box 5 Folder 1-40 Box 4 Folder 1-12 Box 3 Folder 1-29 Box 2 Folder 16-41
Scope and Contents note

Minutes and related records involving ALI members, the Tax Advisory Group, and other participants in the ALI's tax projects.

General Physical Description note

About 6000 items

Scope and Contents note

Initial drafts that outline the objectives of the ALI's Income Tax Project.

General Physical Description note

About 360 items

Scope and Policy Drafts, 1949 February-November. 4 items.
Box 5 Folder 41-44
Scope and Contents note

Initial drafts that outline the objectives of the ALI's Income Tax Project.

Physical Description

4 items

Preliminary Drafts, 1949-1959. About 235 items..
Box 5 Folder 46-59 Box 11 Folder 1 Box 10 Folder 1-41 Box 9 Folder 1-43 Box 8 Folder 1-37 Box 7 Folder 1-39 Box 6 Folder 1-39
Scope and Contents note

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 note

About 235 items.

Discussion Drafts, 1950-1960. 25 items.
Box 12 Folder 1-7 Box 11 Folder 2-20
Physical Description

25 items

Tentative Drafts, 1949-1956. 19 items.
Box 13 Folder 1-7 Box 12 Folder 8-19
Scope and Contents note

Drafts related to the February 1954 draft and the corporate tax law study.

Physical Description

19 items

Foreign Transactions Memoranda, 1951-1952. 9 items.
Box 13 Folder 10-18
Scope and Contents note

Memoranda, officially submitted to the ALI, concerning aspects of the Internal Revenue Code involving foreign tax provisions.

Physical Description

9 items

February 1954 Draft Volumes, 1954 February. 2 items.
Box 13 Folder 8-9
Scope and Contents note

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 Description

2 items

"Income Tax Problems of Corporations and Shareholders" Study Drafts, 1957-1958. 4 items.
Box 16 Folder 1 Box 15 Folder 28-29
Scope and Contents note

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 Description

4 items

Capital Gains Taxation Study Drafts, 1960. 6 items.
Box 16 Folder 4, 6 Box 14 Folder 1-4
Scope and Contents note

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 Description

6 items

Recommendations and Reporters' Studies Drafts, 1961-1968. 48 items.
Box 15 Folder 1-16 Box 14 Folder 5-16 Box 16 Folder 7-26
Scope and Contents note

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 Description

48 items

Other Drafting Records, 1948-1960 and undated. About 30 items.
Box 16 Folder 2-3, 5, 27-28 Box 15 Folder 17-27 Box 13 Folder 19-27 Box 5 Folder 45
Scope and Contents note

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 note

About 30 items

Commentary, 1949-1960. About 100 items.
Box 17 Folder 1-20 Box 16 Folder 29-44
Scope and Contents note

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 note

About 100 items

Article Reprints, 1952-1967. 10 items.
Box 17 Folder 21-31
Scope and Contents note

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 Description

10 items

Print, Suggest