total number of ratifying states to forty-two of the forty-eight then existing: The legislatures of the following states rejected the amendment without ever subsequently ratifying it: Connecticut Rhode Island Utah Virginia The legislatures of the following states never considered the proposed amendment: Florida Pennsylvania Pollock overruled The Sixteenth Amendment removed the precedent set by the Pollock decision. Professor Sheldon D. Pollack at the University of Delaware wrote: From William D. Andrews, Professor of Law, Harvard Law School: From Professor Boris Bittker, who was a tax law professor at Yale Law School: Professor Erik Jensen at Case Western Reserve University Law School has written: Professor Calvin H. Johnson, a tax professor at the University of Texas School of Law, has written: From Gale Ann Norton: From Alan O. Dixler: Congress may impose taxes on income from any source without having to apportion the total dollar amount of tax collected from each state according to each state's population in relation to the total national population. In Wikoff v. Commissioner, the United States Tax Court said: In Abrams v. Commissioner, the Tax Court said: Necessity of amendment In the late 19th century and early 20th century, many legal observers believed that the Supreme Court had erred in designating some income taxes as direct taxes. The Supreme Court had previously rejected the argument that income taxes constituted direct taxes in Springer v. United States (1881). Some legal scholars continue to question whether the Supreme Court ruled correctly in Pollock, but others contend that the original meaning of direct taxes did indeed include income taxes. Case law The federal courts' interpretations of the Sixteenth Amendment have changed considerably over time and there have been many disputes about the applicability of the amendment. The Brushaber case In Brushaber v. Union Pacific Railroad, , the Supreme Court ruled that (1) the Sixteenth Amendment removes the Pollock requirement that certain income taxes (such as taxes on income "derived from real property" that were the subject of the Pollock decision), be apportioned among the states according to population; (2) the federal income tax statute does not violate the Fifth Amendment's prohibition against the government taking property without due process of law; (3) the federal income tax statute does not violate the Article I, Section 8, Clause1 requirement that excises, also known as indirect taxes, be imposed with geographical uniformity. The Kerbaugh-Empire Co. case In Bowers v. Kerbaugh-Empire Co., ,