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The courts have generally held that direct taxes are limited to taxes on people (variously called capitation, poll tax or head tax) and property. (Penn Mutual Indemnity Company. v. C.I.R., 227 F.2d 16, 19-20 (3rd Cir. 1960).) Any other taxes are known as “indirect taxes,” as these tax an event, rather than a person or …
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