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The courts have generally held that direct taxes are restricted to taxes on people (variously called capitation, poll tax or head tax) and property. (Penn Mutual Indemnity Denver. v. C.I.R., 227 F.2d 16, 19-20 (3rd Cir. 1960).) All taxes are typically called "indirect taxes," basically because they tax an event, rather than particular or property as such. (Steward Machine Co. v. Davis, 301 U.S. 548, 581-582 (1937).) What was basically a straightforward limitation on the power of the legislature based on the subject of the tax proved inexact and unclear when applied to an income tax, that can easily be arguably viewed either as a direct or an indirect tax.

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Tax evasion is often a crime. However, in such cases mentioned above, it's simply unfair to an ex-wife. Adage that in this case, evading paying a great ex-husband's due is only one fair contract. This ex-wife cannot stepped on by this scheming ex-husband. A due relief can be a way for that aggrieved ex-wife to somehow evade from a tax debt caused an ex-husband.