"While taxes are an inevitable and legitimate source of government revenue, we cannot tax everything and anything. There must be and exist a legal-rational basis for each tax or tax stream."

“While this court as the tax court will facilitate legitimate collection of tax for the economy, it has the same time, the responsibility to guard against overzealousness in tax collection. While taxes are an inevitable and legitimate source of government revenue, we cannot tax everything and anything. There must be and exist a legal-rational basis for each tax or tax stream. Hence taxation cannot be by sheer caprice, or whim, for the mere sake of taxing, or no reason at all. “