People Places
History Art

Sixteenth Amendment to the United States Constitution

The Sixteenth Amendment to the United States Constitution allows Congress to levy an income tax without apportioning it among the states on the basis of population. It was passed by Congress in 1909 in response to the 1895 Supreme Court case of Pollock v. Farmers' Loan & Trust Co; the Sixteenth Amendment was ratified by the requisite number of states on February 3, 1913, overruled the Supreme Court's ruling in Pollock. Prior to the early 20th century, most federal revenue came from tariffs rather than taxes, although Congress had imposed excise taxes on various goods; the Revenue Act of 1861 had introduced the first federal income tax, but that tax was repealed in 1872. During the late nineteenth century, various groups, including the Populist Party, favored the establishment of a progressive income tax at the federal level; these groups believed that tariffs unfairly taxed the poor, they favored using the income tax to shift the tax burden onto wealthier individuals. The 1894 Wilson–Gorman Tariff Act contained an income tax provision, but the tax was struck down by the Supreme Court in the case of Pollock v. Farmers' Loan & Trust Co.

In its ruling, the Supreme Court did not hold that all federal income taxes were unconstitutional, but rather held that income taxes on rents and interest were direct taxes and thus had to be apportioned among the states on the basis of population. For several years after Pollock, Congress did not attempt to implement another income tax due to concerns that the Supreme Court would strike down any attempt to levy an income tax. In 1909, during the debate over the Payne–Aldrich Tariff Act, Congress proposed the Sixteenth Amendment to the states. Though conservative Republican leaders had expected that the amendment would not be ratified, a coalition of Democrats, progressive Republicans, other groups ensured that the necessary number of states ratified the amendment. Shortly after the amendment was ratified, Congress imposed a federal income tax with the Revenue Act of 1913; the Supreme Court upheld that income tax in the 1916 case of Brushaber v. Union Pacific Railroad Co. and the federal government has continued to levy an income tax since 1913.

The Congress shall have power to lay and collect taxes on incomes, from whatever source derived, without apportionment among the several States, without regard to any census or enumeration. Article I, Section 2, Clause 3: Representatives and direct taxes shall be apportioned among the several States which may be included within this Union, according to their respective Numbers... Article I, Section 8, Clause 1: The Congress shall have Power to lay and collect Taxes, Duties and Excises, to pay the Debts and provide for the common Defence and general Welfare of the United States. Article I, Section 9, Clause 4: No Capitation, or other direct, Tax shall be laid, unless in proportion to the Census or Enumeration herein before directed to be taken; this clause refers to a tax on property, such as a tax based on the value of land, as well as a capitation. Article I, Section 9, Clause 5: No Tax or Duty shall be laid on Articles exported from any State; until 1913, customs duties and excise taxes were the primary sources of federal revenue.

During the War of 1812, Secretary of the Treasury Alexander J. Dallas made the first public proposal for an income tax, but it was never implemented; the Congress did introduce an income tax to fund the Civil War through the Revenue Act of 1861. It levied a flat tax of three percent on annual income above $800; this act was replaced the following year with the Revenue Act of 1862, which levied a graduated tax of three to five percent on income above $600 and specified a termination of income taxation in 1866. The Civil War income taxes, which expired in 1872, proved to be both lucrative and drawing from the more industrialized states, with New York and Massachusetts generating about 60 percent of the total revenue, collected. During the two decades following the expiration of the Civil War income tax, the Greenback movement, the Labor Reform Party, the Populist Party, the Democratic Party and many others called for a graduated income tax; the Socialist Labor Party advocated a graduated income tax in 1887.

The Populist Party "demand a graduated income tax" in its 1892 platform. The Democratic Party, led by William Jennings Bryan, advocated the income tax law passed in 1894, proposed an income tax in its 1908 platform. Proponents of the income tax believed that high tariff rates exacerbated income inequality, wanted to use the income tax to shift the burden of funding the government away from working class consumers and to high-earning businessmen. Before Pollock v. Farmers' Loan & Trust Co. all income taxes had been considered to be indirect taxes imposed without respect to geography, unlike direct taxes, that have to be apportioned among the states according to population. In 1894, an amendment was attached to the Wilson–Gorman Tariff Act that attempted to impose a federal tax of two percent on incomes over $4,000; the federal income tax was favored in the South, it was moderately supported in the eastern North Central states, but it was opposed in the Far West and the Northeastern States. The tax was derided as "un-Democratic and wrong in principle".

In Pollock v. Farmers' Loan & Trust Co. the U. S. Supreme Court declared certain taxes on incomes – such as those on property under the 1894 Act – to be unconstitutionally unapportioned direct taxes; the Court reasoned that a tax on income from property should be treated as a tax on "property by


Adwell is a village and civil parish about 3 miles south of Thame in South Oxfordshire. The parish covers 443 acres, The 2011 Census incorporated its figures into an output area accordingly used to enlarge the civil parish definition of Shirburn to the south, incorporating these two settlements and Stoke Talmage due to their small population. Adwell Cop, 1⁄2 mile southeast of the village, is a 486-foot hill topped with a Bronze Age burial mound. Iron Age pottery has been found nearby; the Cop was erroneously attributed to the Danes, who were in Oxfordshire in AD 1010. Until the Norman conquest of England, a Saxon called Wulfstan held the manor of Adwell, as well as three others in the area including Britwell Salome; the Domesday Book records that by 1086 Advelle had been granted to the Norman Miles Crispin, the first castellan of Wallingford Castle. As such, Adwell became part of the Honour of Wallingford. In 1300 Adwell was escheated to the Crown, it was made part of the Honour of Ewelme. Early in the 19th century Adwell manor was inherited by John H Birch, who took the name Newell Birch as a condition of the legacy.

He left the house in whose family the house has remained. In the 20th century three generations of Birch Reynardson served as High Sheriff of Oxfordshire: WJB Birch Reynardson in 1913, Lieutenant-Colonel Henry Thomas Birch Reynardson CMG in 1958 and Bill Birch Reynardson in 1974; the manor house is Adwell House. There had been a 17th-century house on this site, but it was rebuilt in either the late 18th or early 19th century, it is a Grade II* listed building. Adwell's original parish church is believed to have been built late in the 12th century, although the earliest documentation of it is dated 1254, it had only a chancel. The latter may have been enlarged in the 13th century, judging by its east window, early Decorated Gothic. In the 14th century new windows were inserted in the nave and a new west door was added. In 1553 the building was recorded as having a bell-cot with two bells. All of the walls were repaired around 1800, but by the early 1860s the building was considered too weak to be restored.

The old church building was demolished and in 1865 it was replaced with a new Church of England parish church of Saint Mary designed by the Gothic Revival architect Arthur Blomfield. Blomfield's design replicated the early Decorated style, but the new building retained the south doorway of the old church, in the transitional style between Norman and Early English Gothic; the new church retains the memorials from inside the old one, including a stone effigy of a knight from about 1300. The new building has no aisles, but has north and south chapels arranged as transepts either side of the chancel. There is a bell-cot with one bell; the bell so may be from the old church building. St Mary's parish is now part of the Benefice of Thame; the Oxfordshire Way footpath passes the western edge of the village. Lobel, Mary D, ed.. A History of the County of Oxford. Victoria County History. 8: Lewknor and Pyrton Hundreds. London: Oxford University Press for the Institute of Historical Research. Pp. 7–16. Sherwood, Jennifer.

Oxfordshire. The Buildings of England. Harmondsworth: Penguin Books. P. 419. ISBN 0-14-071045-0. Adwell Parish Meeting Adwell in the Domesday Book


The Nettipakaraṇa is a Buddhist scripture, sometimes included in the Khuddaka Nikaya of Theravada Buddhism's Pali Canon. The main theme of this text is Buddhist Hermeneutics through a systematization of the Buddha's teachings, it is regarded as canonical by the Burmese Theravada tradition, but isn't included in other Theravada canons. The nature of the Nettipakarana was a matter of some disagreement among scholars. Western scholars classified it as a commentary, rather than as a canonical text. Further study and comparison with a related text, the Petakopadesa revealed that it was a guide to interpretation and the composition of definitive commentaries, its translator, supported by Professor George Bond of Northwestern University, described it is a guide to help those who understand the teaching present it to others. However, A. K. Warder disagreed, maintaining that it covers all aspects of interpretation, not just this.. Consensus among contemporary scholars is that it was intended as a guide to interpreting and providing explanation of canonical texts, similar to the Petakopadesa, whose content it resembles.

Verses in the Nettipakarana composed in a poetic meter unknown in Sri Lanka suggest a northern Indian origin for the text that predates the Christian era. It is one of the few post-canonical texts composed in Pāli that predates the work of Buddhaghosa, who quotes from it and uses its methods and technical terms in his own commentaries; the structure of the text- where the verses are constructed as commentaries on a summary verse- became popular in the first centuries CE, while the āryā meter used for its verses was being used for such verses around 150 BCE. The Nettipakarana is ascribed to the Buddha's disciple Kaccana by the text's colophon, introductory verses, the commentary attributed to Dhammapala; the text's colophon says he composed the book, that it was approved by the Buddha and that it was recited at the First Council. Scholars do not take this but the translator admits the methods may go back to him; the translator holds that the book is a revised edition of the Petakopadesa, though this has been questioned by Professor von Hinüber.

K. R. Norman concludes that the Nettipakarana is not a continuation of the Petakopadesa, but a rewritten version that eliminates unimportant content and provides improved and clarified versions of material shared by both sources. Dhammapala composed a commentary on the Nettipakarana, the Nettipakarana-atthakatha, but not the Petakopadesa, a fact that K. R. Norman attributes to the Nettipakarana superseding the older text. Both the use of āryā meter and summary verses suggest a North Indian origin for the text Ujjain, where Buddhist tradition connects the name Mahākaccāna to Avanti, the region suggested as the origin of the Pāli texts brought to Sri Lanka; the text contains quotations from sources outside the Theravada canon, some of which have been traced to texts from the Mulasarvastivada canon. Other quotations are as yet unidentified, but suggest that the Nettipakarana is unusual for being a text drawn from beyond the Theravada tradition that influenced the composition of the definitive commentaries composed by Buddhaghosa.

The Nettipakarana was regarded as canonical by the head of the Burmese sangha around two centuries ago, included in the Khuddaka Nikaya. It is included in the Burmese Phayre manuscript of the Canon, dated 1841/2, the inscriptions of the Canon approved by the Burmese Fifth Council, the 1956 printed edition of the Sixth Council, the new transcript of the Council text being produced under the patronage of the Supreme Patriarch of Thailand and the Sinhalese Buddha Jayanti edition of the Canon. A recent Burmese teacher has not regarded it as canonical; the Nettipakarana is divided into two divisions: Sangahavāra:'Summary', a short section consisting of only five verses that identifies its author as'Mahakaccāna'. Vibhāgavāra:'Explanations', divided into three sub-sections:Uddesavāra Niddesavāra Patiniddesavāra The Uddesavāra enumerates three separate categories: The sixteen hāras are: Desanā, yutti, Padatthāna, Catuvyūha, Āvatta, Parivattana, Vevacana, Paññatti, sodhana, adhitthāna, parikkhāra, samāropana.

The five naya are: Nandiyāvatta. The eighteen mūlapadas consist of nine akusala. Akusala: Tanhā, Lobha, Moha, Subha saññā, Nicca saññā, Sukha saññā. Attasaññā Kusala: samatha, vipassanā, adosa, asubhasaññā, Dukkhasaññā, Aniccasaññā, Anattasaññā The Niddesavāra repeats the hāras and nayas of the previous section along with 12 padas, of which six refer to linguistic forms and six to meaning and describes their relations; the Patiniddesavāra is itself divided into three parts. Each section illustrates technical terms from previous sections by quoting the verses that contain them an