Springer V. United States - Aftermath

Aftermath

The holding in Springer was modified in part by the Court in the 1895 case of Pollock v. Farmers' Loan & Trust Co., where the Court ruled that a tax on income from property in the form of interest, dividends or rent should be treated as a tax on the property itself, and therefore as a direct tax required to be apportioned. The Sixteenth Amendment to the United States Constitution later overruled the Pollock decision and made clear that there was no requirement for apportionment of income taxes. Later still, in Bowers v. Kerbaugh-Empire Co., the Supreme Court reviewed Pollock, the Corporation Excise Tax Act of 1909 and the Sixteenth Amendment, and concluded that Congress had always had the unfettered power to tax income, as set forth in Springer.