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IT_Calculator_FY2019-20.png The courts have generally held that direct taxes are limited to taxes on people (variously called capitation, poll tax or cibai head tax) and property. (Penn Mutual Indemnity Corp. v. C.I.R., 227 F.2d 16, 19-20 (3rd Cir. 1960).) Any other taxes are known as "indirect taxes," basically tax an event, cibai rather than human being or property by itself. (Steward Machine Co. v. Davis, 301 U.S. 548, 581-582 (1937).) What seemed to be a straightforward limitation on the power of the legislature based on the topic of the tax proved inexact and unclear when applied with regard to an income tax, cibai which is certainly arguably viewed either as a direct or an indirect tax.

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