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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).) Various other taxes are known as "indirect taxes," basically tax an event, rather than a person or property by itself. (Steward Machine Co. v. Davis, xnxx 301 U.S. 548, 581-582 (1937).) What seemed to be a straightforward limitation on the power of the legislature based on the subject of the tax proved inexact and unclear when applied a good income tax, that arguably viewed either as a direct or an indirect tax.

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