In 1862 an income tax was enacted to help pay for the Civil WarCivil War. Attorney William Springer refused to pay the income tax on his earnings, arguing that the tax was an invalid direct tax. Justice Noah H. SwayneSwayne, Noah H.Springer v. United States[Springer v. United States] wrote the opinion for the 7-0 majority on the Supreme Court in a case in which Justices Nathan Clifford and Ward Hunt did not participate. Relying on Hylton v. United States[case]Hylton v. United States[Hylton v. United States] (1796) and a uniform practical construction of the U.S. Constitution, Swayne ruled the 1862 income tax to be constitutional. It was not, he stated, a direct tax not apportioned among the states in contravention of the Constitution. This case was not the last word, for the Court in Pollock v. Farmers’ Loan and Trust Co.[case]Pollock v. Farmers’ Loan and Trust Co.[Pollock v. Farmers’ Loan and Trust Co.] (1895) carefully and narrowly construed Springer so that this later Court majority could find the 1894 income tax to be an unconstitutional direct tax. The Sixteenth Amendment authorizing an income tax finally settled this issue.Income tax;Springer v. United States[Springer v. United States]

Hylton v. United States

Income tax

Pollock v. Farmers’ Loan and Trust Co.

Sixteenth Amendment