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 Company. v. C.I.R., 227 F.2d 16, 19-20 (3rd Cir. 1960).) All the other taxes are commonly referred to as "indirect taxes," as these tax an event, rather than particular 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 ...