 The act was controversial even within FDR's United States Treasury Department, as some economists such as Alfred G. Buehler thought that it would harm the ability of business to put capital towards company growth.In particular, Buehler reasoned that the UP tax would hit small business especially hard, as smaller businesses have fewer options in raising capital than large ones, usually by keeping a percentage of their profits for re-investment back into the business.The UP Tax was part of FDR's "Second New Deal".