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 Denver. v. C.I.R., 227 F.2d 16, 19-20 (3rd Cir. 1960).) Various other taxes are known as "indirect taxes," because they tax an event, rather than particular or property by itself. (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 with regard to an income tax, which can be arguably viewed either as a direct or an indirect tax.
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