The United States implemented a graduated federated income tax to pay down the debt accumulated during the United States Civil War. This tax expired in 1872.
Thereafter the federal government relied on tariff revenue and excise taxes to cover debt and pay for services.
In Pollock v. Farmers' Loan & Trust Company (1895), the U.S. Supreme Court held that a tax on dividend income from property was a direct tax, which violated the apportionment rule in Article 1, Section 2, Clause 3 of the United States Constitution. In 1908 or 1909, Nebraska Republican Senator Norris Brown suggested an amendment that would sidestep the apportionment rule and allow direct income taxation.
Ratification of Amendment 16 by three quarters of the legislatures of individual states was completed on February 3, 1913 when the legislature of the state of Delaware assented.
Recited by Paul Turner
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