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. v. C.I.R., 227 F.2d 16, 19-20 (3rd Cir. 1960).) Any other taxes are commonly referred to as "indirect taxes," within their tax an event, rather than human being or property per se. (Steward Machine Co. v. Davis, 301 U.S. 548, 581-582 (1937).) What got a straightforward limitation on the power of the legislature based on the main topic of the tax proved inexact and lanciao unclear when applied with regard to an income tax, which could be arguably viewed either as a direct or an indirect tax.

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