As will be discussed in more detail below , the Pollock court was very clear that it was only a tax on the incomes from property that was a “direct tax,” and other forms of income could be taxed without apportionment. This was confirmed in Brushaber v. Union Pacific . Co. , 240 . 1 (1916). Nevertheless, the Pollock decisions limited the ability of Congress to impose a taxes on incomes, because it was necessary to determine the source of the income. Wages, salaries, and other earned incomes could be taxed, and income from manufacturing and other business activities could be taxed, but rents, interest, dividends, and other incomes from property could not be taxed without apportionment (a very awkward process). The 16th Amendment was therefore proposed by Congress, and ratified by the states, so that Congress could tax incomes “from whatever source derived, without apportionment among the several States, and without regard to any census or enumeration.”
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