A general power is given to Congress, to lay and collect taxes, of every kind or nature, without any restraint, except only on exports; but two rules are prescribed for their government, namely, uniformity and apportionment: Three kinds of taxes, to wit, duties, imposts, and excises by the first rule, and capitation, or other direct taxes, by the second rule.
The federal government brought an action against the debtor to recover a penalty imposed by the act that arose from the debtor's failure to pay a duty on a number of carriages that he kept for his own use for the conveyance of persons. The circuit court noted that the debtor was aware of the act's requirements but that he refused to pay the required duties, alleging that the law was unconstitutional. The circuit court found the debtor liable to pay the tax, and the debtor confessed judgment as the foundation for the writ of error to the Court to try the law's constitutionality. The case was filed with the Supreme Court of the United States.
Is the tax constitutional?
The Court issued seriatim opinions affirming the circuit court's judgment, finding that such a tax was within Congress's power to lay duties and that because a carriage was a consumable commodity, an annual tax on it was on the debtor's expense as owner of the carriages.