The courts have generally held that direct taxes are restricted 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).) Various other taxes are commonly referred to as “indirect taxes,” basically because they tax an event, rather than person or property per se. (Steward Machine Co. v. Davis, 301 U.S. 548, 581-582 (1937).) What got a straightforward limitation on the power of the legislature based on the main topics the tax proved inexact and unclear when applied for kontol income tax, that arguably viewed either as a direct or an indirect tax.
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