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Gouverneur Morris moved to introduce into the Constitution a requirement that “taxation shall be in proportion to Representation.” 1 THE RECORDS OF THE FEDERAL CONVENTION OF 1787, at 591-92 (Max Farrand ed., rev. ed. 1966) Morris then introduced the critical distinction between direct and indirect taxes. He proposed to address the objections “by restraining the rule to direct taxation” so that “[w]ith regard to indirect taxes on exports & imports & on consumption, the rule would be inapplicable.”

Corpus Linguistics of the term "direct tax" THE HORSELESS CARRIAGE OF CONSTITUTIONAL INTERPRETATION: CORPUS LINGUISTICS AND THE MEANING OF “DIRECT TAXES” IN HYLTON v. UNITED STATES “The great object of the Constitution was, to give Congress a power to lay taxes, adequate to the exigencies of government; but they were to observe ... the rule of apportionment, according to the census, when they laid any direct tax." Hylton v. United States, 3 U.S. (3 Dall.) 171, 173 (1796) (opinion of Chase, J.)

Justice Chase likewise thought the constitutional text admitted of no uncertainty. at 173-75 (opinion of Chase, J.); id. at 181 (opinion of Iredell, J.). hylton

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