The decision of the United States Supreme Court in the Pollock case of 1895 was the beginning of an attempt on the part of the court to formulate a new definition of a direct tax, and since that time in every case which has called for a decision as to whether a particular tax was a direct tax the court has reverted to and tried to harmonize its decision with the reasoning set forth in the Pollock case. This decision overturned a fairly definite and universally accepted definition of a direct tax which had existed for nearly a century. In order to understand the new view in contrast with the old we find it necessary to. review briefly the earlier period.
J H. Riddle,
Supreme Court's Theory of a Direct Tax,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol15/iss7/4