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Facts of the Case

Provided by Oyez

In 1794, Congress enacted a tax of sixteen dollars on each carriage owned by an individual or business. Hylton viewed the law as a direct tax in violation of the constitutional requirement that taxes passed by Congress must be apportioned, that is, laid according to the population and the number of representatives from each state.


Questions

  1. Was the carriage tax a direct tax, which would require apportionment among the states? 

Conclusions

  1. The Court concluded that the carriage tax was not a direct tax and thus that the carriage tax did not violate the Article I, Section 2, Clause 3 and Article I, Section 9, Clause 3 requirements for the apportioning of direct taxes. The Court reasoned that direct taxes did not include taxes on the possession of goods.