UCP: TAX 1001_GENERAL PRINCIPLES OF TAXATION FY 2021- 2022

UNIVERSAL COLLEGE OF PARAÑAQUE

COLLEGE OF BUSINESS AND ACCOUNTANCY

INCOME TAXATION
GENERAL PRINCIPLES OF TAXATION

I. Taxation Defined

• Taxation is a mode of raising revenue for public purposes.

• The exercise of the sovereign power to raise revenues for the expenses of the government.
• It is the act of laying a tax, i.e., the process or means by which the taxing power is exercised.

II. Stages or Coverage of Taxation

• Taxation covers three (3) separate areas or aspects of government activity, namely:

1. Levying or imposition of the tax. This involves the passage of tax laws which is generally a
legislative act. In the Philippines, the taxing power is exercised by Congress.

2. Assessment. The process of determining the correct amount of tax due.

3. Collection and payment – the act of compliance with the tax law by the taxpayer.

Note: The acts in (2) and (3) are essentially executive and administrative in nature, meaning it is done by
the BIR.

III. 3 Inherent Powers of a State

1. Power to Tax
2. Police power
3. Power of Eminent Domain

The Power to Tax

• The power to tax is the power by which an Independent State, through its law-making body, raises
and accumulates revenue from its inhabitants to pay the necessary expenses of the government.
• The 1987 Constitution, in Article VI thereof, has vested in Congress the power of tax.
• Congress may make all the laws which shall be necessary and proper for carrying into execution the
foregoing power.
• The power to tax is necessary to the existence and prosperity of a nation as is the air he breathes to the
natural man.
• It is not only the power to destroy, but it is also the power to keep alive.
• To say that “the power to tax is the power to destroy” is to describe not the purpose for which the
taxing power may be used but the degree of vigor with which the taxing power may be employed in
order to raise revenue.
• Subject to inherent and constitutional limitations, the power of taxation is regarded as supreme,
plenary, unlimited, and comprehensive. As long as the legislature, in imposing a tax, does not
violate applicable constitutional limitations or restrictions, the courts have no concern with the wisdom
or policy of the exaction, the political or other collateral motives behind it, the amount to be raised, or
the persons, property, or other privileges to be taxed.

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Police Power

• Police power is the inherent power of a sovereign state to legislate for the protection of the health,
general welfare, safety, and morals of the public. It involves the power to regulate both liberty and
property for the promotion of the public good.
• Note: The police power of the State may be exercised through taxation because taxes may be levied
for the promotion of the welfare of the public.

Power of Eminent Domain

• The power of eminent domain is the inherent power of a sovereign state to take private property for
a public purpose.
• The 1987 Constitution, in Article III, Section 9 thereof, limits the exercise of this power by providing
that: “Private property shall not be taken for public use without just compensation.”

Note:
• All three powers being inherent sovereignty, the same need not be granted by any fundamental law.
They therefore exist independently of the Constitution which instead provides limits to the exercise of
such powers.
• All three powers are legislative in nature and constitute ways by which the state may interfere with the
enjoyment of private rights and properties.

IV. Distinctions Among the Three Inherent Powers

Power of Taxation Police Power Power of Eminent Domain

Purpose To raise revenues for the To promote the general To facilitate the State’s need of
expenses of the State. welfare thru regulations. property for public use.
Amount of Exaction No limit. Limited to the cost of No exaction but private
regulation, issuance of property is taken for public use.
the license, and/or
surveillance.
Benefits Received No special or direct benefit is No direct benefit is A direct benefit results in the
received by an individual received by an form of just compensation to
taxpayer. The public receives individual. A healthy the property owner.
the general benefit of economic standard of
protection of person, property, society is attained.
and the promotion of the
general welfare.
Non-impairment of Obligations in contracts may Obligations in contracts Obligations in contracts may be
contracts* not be impaired by the state may be impaired by the impaired by the government.
where tax exemptions are government.
bilaterally agreed upon by the
state and the taxpayer. Tax
exemptions bilaterally agreed
upon between the government
and the taxpayer cannot be
withdrawn.
Transfer of Property Taxes paid become part of No transfer, but only Transfer is affected in favor of
Rights public funds. restraint in the exercise the State.
of property rights.
Scope All persons, property, rights, All persons, property, Only upon specific property.
and privileges. rights, privileges, and
liberties.
Authority which Exercised by the government or Exercised by the May be exercised by public
exercises the power. its political subdivisions. government or its service corporations or private
political subdivisions. entities operating public
utilities if granted by law.

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Note:
• The purpose of the non-impairment clause of the Constitution is to safeguard the integrity of
contracts against unwarranted interference by the State. As a rule, contracts should not be tampered
with by subsequent laws that would change or modify the rights and obligations of the parties.
Impairment is anything that diminishes the efficacy of the contract. There is an impairment if a
subsequent law changes the terms of a contract between the parties, imposes new conditions, dispenses
with those agreed upon or withdraws remedies for the enforcement of the rights of the parties.
(G.R. No. 195540 March 13, 2013 – GOLDENWAY MERCHANDISING CORPORATION vs.
EQUITABLE PCI BANK)
• Article III, Section 10 of the 1987 Constitution says that “No law impairing the obligation of
contracts shall be passed.”

V. Limitations on the Power to Tax

1. Constitutional Limitations

• These are limitations imposed by the 1987 Constitution:

A) No person shall be deprived of life, liberty, or property without due process of law, nor shall any
person be denied the equal protection of the laws.

Types of Due Process

(1) Substantive due process – which guarantees that a law shall not be unreasonable, arbitrary, or
capricious, and that the means selected shall have a reasonable and substantial relation to the object
being sought; and

(2) Procedural due process – which guarantees fairness in the enforcement of laws which effect
deprivation. The essential elements of procedural due process are notice, and the opportunity to br
heard and to defend in an orderly proceeding adapted to the nature of the case.

B) No person shall be imprisoned for debt or non-payment of a poll tax.

Note: This is a direct head tax. This is easier to collect than other forms of taxes but ignores the “ability
to pay” factor.

C) The rule of taxation shall be uniform and equitable. The Congress shall evolve a progressive
system of taxation.

Uniformity – means the same class of persons or properties falling under the same circumstances
should be taxed the same kind and rate of tax.

Equality – requires no more than that the same means and methods be applied impartially to all the
constituents of each class, so that the law shall operate equally and uniformly upon all persons in
similar circumstances.

Equal protection of the law – means equality before the law. However, such equality does not deny
to the state the power to recognize factual differences between individuals and classes. It recognizes
that inherent in the right to legislate is the right to classify, provided that it is a valid and reasonable
classification. If the groupings are characterized by substantial distinctions that make real differences,
one class may be treated and regulated differently from another.

Equitability – requires that the total tax burden be apportioned based on the taxpayer’s ability to bear
the tax burden which is to be achieved thru a progressive system of taxation (Fr. Joaquin Bernas, S.J.).

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Can perfect uniformity and perfect equality of taxation be achieved?

• No. Perfect uniformity and perfect equality of taxation in all the aspects in which the human mind
can view it, is a baseless dream.

D) Charitable institutions, churches, and parsonages, or convents appurtenant thereto, mosques, non-
profit cemeteries, and all lands, buildings, and improvements, actually, directly, and exclusively
used for religious, charitable, or educational purposes shall be exempt from taxation.
Note: The exemption referred to here is exemption from the real property tax which is a local tax
levied by a province or city (not by the National Government).

E) No law granting any tax exemption shall be passed without the concurrence of a majority of all
the members of Congress.

F) No law impairing the obligation of contracts shall be passed.

Notes:

i) When the tax exemption is bilaterally agreed upon between the government and the taxpayer,
the exemption cannot be withdrawn without violating the non- impairment clause.
ii) However, when the tax exemption is unilaterally granted by law, the same may be withdrawn
by virtue of another law without violating the non-impairment clause.
iii) When the tax exemption is granted under a franchise embodied in a law, the same may be
withdrawn at any time.

G) No law shall be passed adbridging the freedom of speech, of expression, or of the press.

H) No law shall be made respecting an establishment of a religion or prohibiting the free exercise
thereof.
• No public money or property shall be appropriated, applied, paid, or employed, directly or
indirectly for the use, benefit, or support of any sect, church, denomination, sectarian institution,
or system of religion, or of any priest, preacher, minister, or other religious teacher or dignitary as
such except when such priest, preacher, minister or dignitary is assigned to the armed forces
or to any penal institution, or government orphanage or leprosarium.

I) All appropriation, revenue or tariff bills shall originate exclusively in the House of
Representatives, but the Senate may propose or concur with amendments.

J) The Congress may, by law, authorize the President to fix within specified limits, and subject to
such limitations and restrictions as it may impose, tariff rates, import and export quotas, tonnage
and wharfage dues, and other duties or imposts within the framework of the national development
program of the Government.

K) The Supreme Court shall have the power to review, revise, reverse, modify, or affirm on appeal
or certiorari as the law or the Rules of Court may provide, final judgments and orders of lower
courts in all cases involving the legality of any tax, impost, assessment, or toll, or any penalty
imposed in relation thereto.

L) All appropriation, revenue or tariff bills shall originate exclusively in the House of
Representatives, but the Senate may propose or concur with amendments.

M) All revenues and assets of non-stock, non-profit educational institutions used actually, directly,
and exclusively for educational purposes shall be exempt from taxes and duties.

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Note: Real properties of non-stock, non-profit educational institutions are exempt from real property
taxes which are imposed by the local government. Provided such properties are actually, directly, and
exclusively used for educational purposes.
Note: Moreover, income of a non-stock, non-profit educational institution derived from any activity
or property shall be exempt from income taxation as long as such income is used actually, directly,
and exclusively for educational purposes (CIR vs. De La Salle, Inc., Supreme Court G.R. No. 196596,
November 2, 2016).
N) The President shall have the power to veto any particular item or items in an appropriation,
revenue, or tariff bill, but the veto shall not affect the item or items to which he does not object.

O) All money collected or any tax levied for a special purpose shall be treated as a special fund and
paid out for such purpose only. If the purpose for which a special fund was created has been
fulfilled or abandoned, the balance, if any, shall be transferred to the general funds of the
Government.

2. Inherent Limitations

• These are restrictions arising from the very nature of the power to tax itself. They are:

A) The levy must apply within territorial limits for the exercise of effective tax jurisdiction.

B) The tax must be for a public purpose. No tax law may be enacted for the purpose of raising
revenue for private purposes.

C) Exemption from taxation of the government, any political subdivision thereof, or agencies
performing purely governmental functions

Example: City Government of Makati

However, when a local government unit (LGU), government agency, or government owned and
controlled corporation engages in activities which are proprietary in character (i.e. engaging in
businesses and activities similar to those performed by other taxable corporations), such LGU,
government agency, or GOCC shall be subject to both income and business taxes as other private
corporations. Examples are Land Bank of the Philippines; PAGCOR.

Exclusions: The Government Service Insurance System (GSIS), the Social Security System (SSS),
Home Development Mutual Fund (Pag-Ibig), the Philippine Health Insurance Corporation (PHIC
or Philhealth), and local water districts (LWDs); are exempt from the income tax imposed under
Section 27 of the National Internal Revenue Code (“NIRC”).

For a government entity to be taxable, the following must concur:

(1) It must not be performing an essential governmental function.
(2) It must be engaged in a similar business, industry, or activity as performed by other taxable
corporations.

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D) As a general rule, the taxing power of the legislature may not be delegated. Exceptions to this
non-delegability rule are:

i) The authority of the President to fix tariff rates, import and export quotas, tonnage and
wharfage dues, and other duties and imposts (Art. VI, Sec. 28 (2), 1987 Constitution).

ii) Each local government unit shall have the power to create its own sources of revenues
and to levy taxes, fees, and charges subject to such guidelines and limitations as the
Congress may provide, consistent with the basic policy of local autonomy. Such taxes, fees,
and charges shall accrue exclusively to the local governments (Art. X, Sec. 5, 1987
Constitution). Ex. Real property taxes.

iii) Delegation to administrative agencies for implementation of the tax laws, and collection of
the tax to the BIR.

E) International Comity

Under Article II, Section 12 of the 1987 Constitution, the Philippines adopts the generally accepted
principles of international law as part of the law of the land, and adheres to the policy of peace,
equality, justice, freedom, cooperation, and amity with all nations.

This principle limits the authority of the government to effectively impose taxes on a sovereign
state and its instrumentalities, as well as on its property held and activities undertaken in that
capacity. As a rule, the Philippine government cannot tax foreign ambassadors nor impose
real property taxes upon foreign embassies.

F) Direct Double Taxation

• Means taxing twice, for the same purpose, in the same year. To constitute double taxation – two
or more taxes must be:
(1) The same subject is taxed twice;
(2) By the same taxing authority;
(3) Within the same jurisdiction;
(4) During the same taxing period; and
(5) Covering the same kind or character of tax (Villanueva v. City of Iloilo, L-26521).

• There is no constitutional prohibition against double taxation in the Philippines (Villanueva v.

City of Iloilo, L-26521, December 28, 1968), though it is not favoured.
• Indirect double taxation, which lacks one or more of the elements of direct double
taxation, is also permissible.

VI. Basic Principles of a Sound Tax System

1. Fiscal Adequacy – which means that the sources of revenue should be sufficient to meet the
demands of public expenditures;
2. Equality or Theoretical Justice – which means that the tax imposed should be proportionate to
the taxpayer’s ability to pay; and
3. Administrative Feasibility – which means that the tax laws should be capable of convenient, just,
and effective administration.

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VII. Theory or Basis of Taxation

1. Life-blood Theory - Taxes are the lifeblood of the government. Without taxes, no government
can function.
2. Benefits Protection Theory (Symbiotic Relationship) - Taxes are what we pay for a civilized or
organized society. Without taxes, the government would be paralyzed for lack of the motive power
to activate and operate it (Commissioner v. Algue, 158 SCRA 9)

VIII. Tax Defined

• Tax is the enforced proportional contribution from persons and property, levied by the State, by
virtue of its sovereignty, for the support of government and for all public needs.
• A tax has been defined as an enforced, proportional, pecuniary contribution, from persons and
property within the taxing jurisdiction, levied by the State by virtue of its sovereign power to tax,
to raise revenue for the support of the government and for its public needs.

IX. Essential Elements or Characteristics of a Tax

1. Enforced contribution
2. Exacted pursuant to legislative authority
3. For raising revenue for public needs
4.Proportionate in character or uniform
5. Payable in money
6. Imposed within the state’s jurisdiction
7. Personal to the taxpayer

X. Canons of a Tax

1. Proportional to one’s ability to pay

2. Certain and not arbitrary
3. Convenient to pay
4. Economical to collect

XI. Classification of Taxes

Classification Definition Example

According to scope or exercising authority
National Tax Imposed by the National Income tax, Estate tax, Donor’s
Government tax, VAT, OPT, Excise Tax,
DST
Municipal or Local Tax Imposed by local government Occupation tax, Real property
units tax (RPT)
According to subject matter or object
Personal, capitation, or poll Fixed amount imposed upon Community tax
tax persons of a certain class without
regard to property, trade,
business, or occupation.
Property Tax Imposed on property Real Property Tax
Excise Tax Imposed upon the performance VAT, Donor’s tax, Estate tax,
of an act; the exercise of a right; Income tax, Occupation tax,
or the engaging in business or Excise tax
profession
According to who bears the burden of the tax
Direct Tax The liability for the tax (impact), Income tax
and the burden thereof

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(incidence) fall on the same

taxpayer
Indirect Tax The liability or impact for the tax VAT, excise tax, custom duties
falls on the original taxpayer, but
the burden or incidence thereof
is shifted to another.
According to purpose
General or Revenue Tax Levied without a specific or pre- Income tax, VAT, etc.
determined purpose
Special Tax Levied for a special purpose Protective tariffs; special
assessments
According to the rate applied
Proportional Based on a fixed percentage of RPT, VAT, Donor’s tax, Estate
the tax base. tax.
Progressive The tax rate increases as the tax Income tax on individuals under
base increases. the graduated rates
Regressive The tax rate decreases as the tax None. It is not applied in the
base increases. Philippines.
According to measurement of the amount due
Specific Measured by number, or based Excise tax on lubricating oils,
on weight or physical waxes, petroleum, etc.
measurement.
Ad Valorem Based on the value of the RPT; excise tax on liquors,
property and may require the cigarettes packed by machine,
intervention of assessors and and automobiles
appraisers.

XII. Nature or Construction of Tax Laws

1. Tax laws are prospective, generally, but can have retrospective application.

• The constitutional prohibition against the passage of laws having retrospective application (all
called ex post facto legislation) is limited to penal or criminal statutes.
• Tax laws, like other statutes, are to be construed as having only a prospective operation unless the
purpose and intention of the legislature to give retrospective effect is expressly declared or is
necessarily implied from the language used.
• There is presumption that the legislative intended its amendment to operate only in the future. Lex
prospicit, non respicit (the laws look forward not backward). And in case of any doubt, the doubt
must be resolved against retrospective operation.

2. A statute will not be construed as imposing a tax unless it does so clearly, and
unambiguously.

• A tax cannot be imposed without clear and express words for that purpose. Accordingly, the
provisions of a taxing act are not to be extended by implication.
• In case of doubt, statutes imposing a tax are construed most strongly against the
Government, and liberally in favor of the citizen because burdens are not to be imposed beyond
what the statutes expressly can clearly import.

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3. Tax exemptions are to be construed strictly against the taxpayer.

• Legal provisions providing for tax exemptions are to be construed strictly against the grant and
liberally in favor of the taxing power.
• Exemption from taxation is construed strictissimi juris, i.e., strictly against exemption. Hence,
exemption must be anchored firmly on an express provision of law. He who claims exemption
must be able to justify his claims by the clearest grant of organic and statute law.

4. Revenue laws are not political in nature.

• Our internal revenue laws are not political in nature and as such were continued in force during
the period of enemy occupation and in effect were actually enforced by the occupation government.

5. Legislative intention must be considered.

• Tax statutes are to receive a reasonable construction with a view to carrying out their purpose and
intent.

6. In case of doubt, tax statutes are construed most strongly against the Government, and
liberally in favor of the citizen

• Because burdens are not to be imposed beyond what the statutes expressly can clearly import.

7. Tax laws are special laws, and prevail over general laws.

8. Tax laws are not penal in character

• Being civil in nature, the constitutional prohibition against ex post facto legislation does not apply
to tax laws. They can therefore be given retrospective application if expressly declared by the tax
law.
• A tax creates a civil obligation or liability on the part of the taxpayer, although the non- payment
thereof creates a criminal liability, which could be the subject of criminal prosecution under
existing laws. In short, in taxation, it is one’s civil liability to pay taxes that gives rise to criminal
liability.
Note: Ex post facto is defined as a law which provides for the infliction of punishment upon a person
for an act done which, when it was committed, was innocent, or a law which aggravates a crime or
makes it greater than when it was committed.

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XIII. Sources of Tax Laws

1. The 1987 Constitution;
2. Tax statutes such as the National Internal Revenue Code (“NIRC”), the Tariff and Customs
Code, the VAT Law, the Revised Documentary Stamp Tax Law, the Amended Excise Tax Law,
and portions of the Local Government Code;
3. Executive orders on taxation, and local tax ordinances;
4. Tax treaties and conventions with foreign countries;
5. Judicial decisions;
6. Rules and regulations promulgated by the Department of Finance, the Bureau of Internal
Revenue (“BIR”), Bureau of Customs, etc.
7. Administrative interpretations and opinions of tax officials particularly those of the
Commissioner of Internal Revenue.

XIV. Forms of Escape from Taxation

1. Shifting the burden of the tax – this involves transferring the burden of the tax from the
statutory taxpayer to another without violating the tax law.

2. Capitalization - by not selling property which has increased in value, the owner avoids the
income tax to be paid on the gain if the same is sold. An increase in the value of an asset is
merely an unrealized increase (gain) in capital.

3. Transformation - the manufacturer or producer upon whom the tax has been imposed, fearing
the loss of his market if he should add the tax to the price, pays the tax. He then endeavors to
recoup the tax paid by making his production more efficient and lowering his cost of
production.

4. Tax exemption - exemption from taxation is the freedom from the burden of paying tax.

5. Tax avoidance - occurs when the means used to minimize taxes are legal and not prohibited
by law.

6. Tax evasion - connotes fraud through the use of pretenses and forbidden devices to lessen or
defeat taxes.

XV. Tax vs other terms

A. Tax and License Distinguished

Tax License
Purpose To raise revenue To regulate action, businesses,
industries, professions
Limitations on Subject to constitutional and inherent Not subject to the limitations on taxation
taxation limitations on the power to tax
Amount Unlimited Limited to the cost of regulation
(Licensing, inspection, surveillance)
Effect of non- Does not make the business illegal Makes the business illegal
payment

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B. Tax and Special Assessment Distinguished

Tax Special Assessment
Imposed on all property (real or personal) in a Imposed only on property which benefit from
prescribed area the improvement

• A special assessment is in the nature of a tax upon property levied according to benefits conferred
on the property. The whole theory of a special assessment is based on the doctrine that the property
against which it is levied derives some special benefit from the improvement xxxxxxx their
property being increased in value by the expenditure to an amount at least equal to the sum they
are required to pay.

• Tax and Special Assessment Distinguished

1. A special assessment can be levied only on land;
2. A special assessment cannot (at least in most states) be made a personal liability of the
person assessed;
3. A special assessment is based wholly on benefits; and
4. A special assessment is exceptional both as to time and locality.

C. Tax and Debt Distinguished

Tax Debt
Source of obligations Law Contract
Obligee Due to the government in its Due to obligee under a contract;
sovereign capacity May be due to the government
in its corporate capacity
Form of payment Money Money, property, or services
Interest No interest except in cases of If stipulated or if the payment is
delinquency in delay
Assignability Not assignable Generally assignable
Compensation/Set-off No Yes
Incarceration for non- payment Yes, except for non- No person can be imprisoned
payment of poll tax for non-payment of debts
(Constitution).

D. Tax and Toll Distinguished

Tax Toll
Demand for sovereignty Demand of ownership or proprietorship
Imposed by the government May be imposed by private persons or entities
May be based on income or on the value of Largely based on the cost of the property used, or on
the property the cost of the improvement used
Forced contribution Compensation charged by the owner for the
voluntary use of the property/improvements

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XVI. Taxes Imposed under the National Internal Revenue Code (“NIRC”)

1. Income tax
2. Estate tax
3. Donor’s tax
4. Value-added tax (“VAT”)
5. Other percentage taxes (“OPT”)
6. Excise taxes
7. Documentary stamp taxes

XVII. Tax Administration

• It is a system involving assessment, collection, and enforcement of taxes, including the

execution of judgment in all tax cases decided in favor of the Bureau of Internal
Revenue by the courts.

Powers and Duties of the Bureau of Internal Revenue (“BIR”)

1. The assessment and collection of all national internal revenue taxes, fees, and
charges;
2. The enforcement of all forfeitures, penalties, and fines connected therewith;
3. The execution of judgments in all cases decided in its favor by the Court of Tax
Appeals, and the ordinary courts;
4. The giving effect to and the administering of the supervisory and police power
conferred to it by the Tax Code or other laws.

Powers of the Commissioner of Internal Revenue (“CIR”)

1. Power to interpret tax laws subject to review by the Secretary of Finance;

2. Power to decide disputed assessments, refunds of internal revenue taxes, fees and other
charges, penalties imposed in relation thereto, other matters arising under the National
Internal Revenue Code (“NIRC”) or other laws or portions thereof administered by the
Bureau of Internal Revenue (“BIR”), subject to the exclusive appellate jurisdiction of the
Court of Tax Appeals (“CTA”);

3. Power to examine any book, paper, record, or other data which may be relevant or material
to a tax inquiry;

4. Power to obtain information from any person other than the person whose internal revenue
tax liability is subject to audit or investigation or from any office or officer of the national
or local governments, government agencies and instrumentalities;

5. Power to summon the person liable for tax or required to file a return, or any officer or
employee of such person, or any person having possession, custody, or care of the books
of accounts and other accounting records;

6. Power to take such testimony of the person concerned, under oath, as may be relevant or
material to such inquiry;

7. Power to make assessments.

8. Power to prescribe real property values by dividing the country into different zones and
determining the FMV of real properties located in each zone;

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9. The Commissioner is authorized to inquire into the bank deposits and other related
information held by financial institutions of:
(a) A decedent to determine his gross estate;
(b) A taxpayer who has filed an application for compromise of his tax liability by
reason of financial incapacity to pay his tax liability; and
(c) A taxpayer who is subject of a request for the supply of tax information from a
foreign tax authority pursuant to an international agreement or treaty.

10. The Commissioner has the authority to accredit and register individuals and general
professional partnerships (GPPs) and their representatives who prepare and file tax returns,
statements, reports, and other papers, or who appear before the BIR, for taxpayers.

11. Power to prescribe additional procedural or documentary requirements in connection with

the submission or preparation of financial statements accompanying the tax returns.

“Never give up, for that is just the place and time that the tide will turn.”
- Harriet Beecher Stowe

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