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 Organization. v.
C.I.R., 227 F.2d 16, 19-20 (3rd Cir. 1960).) All the other taxes are known as "indirect taxes," because they tax an event, rather than a person or property as such. (Steward Machine Co. v. Davis, 301 U.S. 548, 581-582 (1937).) What were a straightforward limitation on the power of the legislature based on the main topic of the tax proved inexact and unclear when applied for income tax, that will be arguably viewed either as a direct or an indirect tax.
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