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 the 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 a straightforward limitation on the power of the legislature based on the main topic...