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In Pollock v. Farmers' Loan & Trust Co. (1895), the U.S. Supreme Court ruled that the income tax imposed by the Wilson-Gorman Tariff Act of 1894 was unconstitutional. The Court held that the tax on income derived from property was a direct tax that needed to be apportioned among the states according to the Constitution. This decision effectively invalidated the federal income tax until the Sixteenth Amendment was ratified in 1913, allowing Congress to levy income taxes without apportionment.

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