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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).) All taxes are typically called "indirect taxes," basically because they tax an event, rather than somebody or property as such. (Steward Machine Co. v. Davis, 301 U.S.

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