The courts have generally held that direct taxes are restricted to taxes on people (variously called capitation, poll tax or head tax) and anjing property. (Penn Mutual Indemnity Denver colorado.
v. C.I.R., 227 F.2d 16, 19-20 (3rd Cir. 1960).) All the taxes are typically called “indirect taxes,” because they tax an event, rather than human being 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 topic of the tax proved inexact and lanciao unclear when applied to an income tax, that can easily be arguably viewed either as a direct or an indirect tax.
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