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., 227 F.2d 16, 19-20 (3rd Cir. 1960).) All other taxes are commonly referred to as "indirect taxes," basically because they tax an event, rather than an individual 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 ...