Discussion
In Brushaber the Court noted that even before the Sixteenth Amendment was passed, the Congress had authority to tax income. If a particular income tax was a direct tax or was treated as a direct tax in the constitutional sense, that tax could be imposed (after Pollock but before the passage of the Amendment) only by apportionment among the states, according to their census populations.
In Brushaber, the Court held that the Sixteenth Amendment eliminated the requirement of apportionment as it relates to "taxes on incomes, from whatever source derived."
Read more about this topic: Brushaber V. Union Pacific Railroad
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