The courts have generally held that direct taxes are limited to taxes on people (variously called capitation, kontol poll tax or head tax) and property. (Penn Mutual Indemnity Denver. v. C.I.R., 227 F.2d 16, bokep 19-20 (3rd Cir. 1960).) All other taxes are known as “indirect taxes,” as these tax an event, rather than a person or property per se. (Steward Machine Co. v. Davis, memek 301 U.S. 548, 581-582 (1937).) What were a straightforward limitation on the power of the legislature based on the topic of the tax proved inexact and unclear when applied to an income tax, which is certainly arguably viewed either as a direct or an indirect tax.

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