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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).) Any other taxes are typically called "indirect taxes," as these tax an event, rather than person or property by itself. (Steward Machine Co. v. Davis, 301 U.S. 548, 581-582 (1937).) What was a straightforward limitation on the power of the legislature based on the main topic of the tax proved inexact and unclear when applied to an income tax, which could be arguably viewed either as a direct or an indirect tax.

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This law extended the existing tax rate structure for single taxpayers with taxable income of compared to USD 400,000, kontol and married taxpayers with taxable income of less than USD 450,000.