A tax called the undistributed profits tax was enacted in 1936.
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But from 1 July 1967 the law on undistributed profits tax changed and Francis Richards as constituted could no longer serve that purpose.
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Flanders reported, however, that when the committee made its recommendations President Roosevelt was preoccupied with augmenting the Supreme Court and ultimately chose the undistributed profits tax instead a choice that Flanders felt discouraged capital investment.
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Oliphant later went on to teach at Johns Hopkins University, and later became the chief counsel of the United States Treasury Department, serving in that capacity from 1934 to 1939 . While serving in that position, he was regarded as an economic experimenter, and was the prime advocate of the Undistributed profits tax.
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