Xnxx 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 Co. v. C.I.R., 227 F.2d 16, 19-20 (3rd Cir. 1960).) All 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 were a straightforward limitation on the power of the legislature based on the ...