The courts have generally held that direct taxes are limited to taxes on people (variously called capitation, poll tax or head tax) and property. (Penn Mutual Indemnity Co. v. C.I.R., bokep 227 F.2d 16, 19-20 (3rd Cir. 1960).) All taxes are known as "indirect taxes," basically because they tax an event, rather than person or property per se. (Steward Machine Co. v. Davis, lanciao 301 U.S. 548, 581-582 (1937).) What turned out to be a straightforward limitation on the power of the legislature based on the main topic of the tax proved inexact and unclear when applied with regard to an income tax, that can easily be arguably viewed either as a direct or an indirect tax.

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