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Revision as of 20:14, 10 May 2026


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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 Corp. v. C.I.R., 227 F.2d 16, 19-20 (3rd Cir. 1960).) All the other taxes are typically called "indirect taxes," basically tax an event, rather than a person 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 subject of the tax proved inexact and unclear when applied for income tax, which is certainly arguably viewed either as a direct or an indirect tax.

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The auditor going using your books does not necessarily want transfer pricing find out a problem, but he's to choose a problem. It's his job, and he has to justify it, and also the time he takes to make it work.

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