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The courts have generally held that direct taxes are restricted to taxes on people (variously called capitation, poll tax or head tax) and property. (Penn Mutual Indemnity Company. v. C.I.R., xnxx 227 F.2d 16, 19-20 (3rd Cir. 1960).) Various other taxes are commonly referred to as "indirect taxes," as these tax an event, rather than a person or property per se. (Steward Machine Co. v. Davis, 301 U.S. 548, 581-582 (1937).) What seemed to be a straightforward limitation on the power of the legislature based on the main topic of the tax proved inexact and unclear when applied a good income tax, that can easily be arguably viewed either as a direct or an indirect tax.

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