History Among The Federal Taxes
The courts have generally held that direct taxes are limited to taxes on people (variously called capitation, poll tax or head tax) and property. (Penn Mutual Indemnity Corp. v. C.I.R., 227 F.2d 16, 19-20 (3rd Cir. 1960).) All taxes are known as "indirect taxes," as these tax an event, rather than somebody or property as such. (Steward Machine Co. v. Davis, 301 U.S. 548, 581-582 (1937).) What was basically a straightforward limitation on the power of the legislature based on the main topics the tax proved inexact and unclear when applied a good income tax, that will be arguably viewed either as a direct or an indirect tax.
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