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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 Organization. v. C.I.R., 227 F.2d 16, 19-20 (3rd Cir. 1960).) All taxes are commonly referred to as "indirect taxes," within their tax an event, rather than particular or property as such. (Steward Machine Co. v. Davis, 301 U.S. 548, 581-582 (1937).) What got a straightforward limitation on the powe...
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