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," within their tax an event, rather than somebody or property per se. (Steward Machine Co. v. Davis, 301 U.S. 548, 581-582 (1937).) What was basically a straightforward limitation on the power of the legislature ...