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The courts have generally held that xnxx taxes are limited to taxes on people (variously called capitation, poll tax or head tax) and property. (Penn Mutual Indemnity Denver colorado. v. C.I.R., 227 F.2d 16, 19-20 (3rd Cir. 1960).) All the taxes are commonly referred to as "indirect taxes," basically tax an event, rather than particular or property per se. (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 income tax, that can easily be arguably viewed either as a direct or an indirect tax.

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