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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 Company. v. C.I.R., 227 F.2d 16, 19-20 (3rd Cir. 1960).) All other taxes are commonly referred to as "indirect taxes," within their tax an event, rather than 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, which could be arguably viewed either as a direct or an indirect tax.

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In addition, the exclusion is only one good thing that extra. The income level wherein each income tax bracket applies has also been increased for inflation.

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