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(1) The power of taxation proceeds upon the theory that the existence of government
is a necessity; that it cannot continue without the means to pay its expenses; and that
for these means it has a right to compel all its citizens and property within its limits to
contribute. As said in case:
“The power to tax is an attribute of sovereignty emanating from necessity. It is a
necessary burden to preserve the State’s sovereignty and a means to give the citizenry
an army to resist aggression, a navy to defend its shores from invasion, a corps of civil
servants to serve, public improvements designed for the enjoyment of the citizenry and
those which come within the States territory, and facilities and protection which a
government is supposed to provide.”
(2) The basis of taxation is found in the reciprocal duties of protection and support
between the state and its inhabitants. In return for his contribution, the taxpayer
receives the general advantages and protection which the government affords the
taxpayer and his property. This is the so-called benefits-received principle. One is
compensation or consideration for the other: protection for support and support for
protection.