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cibai The courts have generally held that direct taxes are limited to taxes on people (variously called capitation, poll tax or head tax) and anjing property. (Penn Mutual Indemnity Denver. v. C.I.R., 227 F.2d 16, lanciao 19-20 (3rd Cir. 1960).) All taxes are known as "indirect taxes," basically tax an event, rather than an individual or property as such. (Steward Machine Co. v. Davis, 301 U.S. 548, 581-582 (1937).) What turned out to be a straightforward limitation on the power of the legislature based on the topic of the tax proved inexact and unclear when applied for income tax, which can be arguably viewed either as a direct or an indirect tax.

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