From the time when the Federal income tax was first imposed until his death the returns of the deceased taxpayer's income was made up for an accounting period substituted for the twelve months ending 30th June preceding the financial year for which income tax was payable. The accounting period consisted of the calendar year and in his case income tax was levied and paid for each financial year upon income derived by him during the calendar year which closed six months before the commencement of the financial year. He died on 17th April 1934. For the financial year then current, namely, that ending on 30th June 1934, he had been assessed upon his income derived during the calendar year 1932. For the next financial year after his death, that beginning on 1st July 1934, his executors have been assessed to income tax upon the income derived by him during the calendar year 1933. They object that they are under no liability for income tax for that financial year. Their testator was dead before it began. For the last financial years of his life he had paid income tax and on his death he ceased to be a taxpayer. Federal income tax, they say, is levied upon persons, not upon property. It is a tax upon a man in respect of his income. It is imposed upon him for the financial year and measured by his income of the immediately preceding twelve months or for some other substituted accounting period. The financial year is the period in and for which he incurs liability. His income for the preceding period is not a fund subject to an impersonal levy or charge, but is a basis for calculating his personal liability. Accordingly, the executors say, the estate of the deceased taxpayer falls under no liability to income tax for the financial year following his death, unless in the legislation some special charging provision can be found imposing the liability in clear terms. It is conceded that in the Income Tax Assessment Act 1915-1921 such a provision existed. Sec. 46C of that Act, which was introduced into it by Act No. 18 of 1918, provided that, where a person dies during a financial year and his estate is not liable to duty under the Estate Duty Assessment Act 1914, the executors or administrators of that person shall furnish a return of the income derived by that person during the financial year up to the date of his death, and shall be liable for tax in respect of that income. The last words of the section imposed a liability in express terms. The provision was limited to cases where estate duty was not payable, evidently upon the view that the intermediate income derived between the beginning of the previous financial year and death ought not to be taxed except in that event. The executors rely upon these features as confirming their view that liability to tax in respect of that income would not arise out of the general provisions of the Assessment Act and that nothing but a special charging section expressed in clear terms would suffice to impose it. They deny that this is done by any provision of the Income Tax Assessment Act 1922-1934. In that Act sec. 62 replaces secs. 46A, 46B and 46C of the earlier Assessment Act. Sub-sec. 1 of sec. 62 is as follows: