The courts have generally held that direct taxes are restricted to taxes on people (variously called capitation, poll tax or cibai head tax) and property. (Penn Mutual Indemnity Company. v. C.I.R., 227 F.2d 16, 19-20 (3rd Cir. 1960).) All other taxes are typically called “indirect taxes,” because they tax an event, rather than person or property by itself. (Steward Machine Co. v. Davis, 301 U.S. 548, 581-582 (1937).) What seemed to be a straightforward limitation on the power of the legislature based on the main topic of the tax proved inexact and unclear when applied for bokep income tax, that arguably viewed either as a direct or an indirect tax.
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