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==Progressive Era==
 
==Progressive Era==
In 1894, as part of the Wilson-Gorman tariff bill, Congress enacted a 2-percent tax on income over $4,000. The tax in 1895 was struck down by a five-to-four decision of the U.S. Supreme Court in ''Pollock v. Farmers' Loan & Trust Co.'' It held unconstitutional any direct tax by Congress on income.  A tax on income derived from property was a ''direct tax'' which Congress could impose only by the rule of apportionment according to population pursuant to Article I, Secs. 2 and 9 of the Constitution.  The ''Pollock'' decision was a surprise because merely 15 years earlier the Supreme Court had unanimously upheld a similar tax during the Civil War, the only other time that Congress had tried to tax income directly.
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In 1894, as part of the Wilson-Gorman Tariff bill, Congress enacted a 2-percent tax on income over $4,000. The tax in 1895 was struck down by a five-to-four decision of the U.S. Supreme Court in ''Pollock v. Farmers' Loan & Trust Co.'' It held unconstitutional any direct tax by Congress on income.  A tax on income derived from property was a ''direct tax'' which Congress could impose only by the rule of apportionment according to population pursuant to Article I, Secs. 2 and 9 of the Constitution.  The ''Pollock'' decision was a surprise because merely 15 years earlier the Supreme Court had unanimously upheld a similar tax during the Civil War, the only other time that Congress had tried to tax income directly.
    
Although radicals denounced the Court's decision as a prime example of the alliance of government and business against the farmer, a general return of prosperity around the turn of the century softened the demand for reform. Democratic Party Platforms under the leadership of three-time Presidential candidate William Jennings Bryan, however, consistently included an income tax plank, and the progressive wing of the Republican Party also espoused the concept.
 
Although radicals denounced the Court's decision as a prime example of the alliance of government and business against the farmer, a general return of prosperity around the turn of the century softened the demand for reform. Democratic Party Platforms under the leadership of three-time Presidential candidate William Jennings Bryan, however, consistently included an income tax plank, and the progressive wing of the Republican Party also espoused the concept.
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