property, a federal income tax was impractical from the time of the Pollock decision until the time of ratification of the Sixteenth Amendment (below). 16th Amendment In response to the Supreme Court decision in the Pollock case, Congress proposed the Sixteenth Amendment, which was ratified in 1913, and which states: The Congress shall have the power to lay and collect taxes on incomes, from whatever source derived, without apportionment among the several States, and without regard to any census or enumeration. The Supreme Court in Brushaber v. Union Pacific Railroad, , indicated that the Sixteenth Amendment did not expand the federal government's existing power to tax income (meaning profit or gain from any source) but rather removed the possibility of classifying an income tax as a direct tax based on the source of the income. The Amendment removed the need for the income tax on interest, dividends, and rents to be apportioned among the states based on population. Income taxes are required, however, to abide by the law of geographical uniformity. Congress enacted an income tax in October 1913 as part of the Revenue Act of 1913, levying a 1% tax on net personal incomes above $3,000, with a 6% surtax on incomes above $500,000. By 1918, the top rate of the income tax was increased to 77% (on income over $1,000,000, equivalent of $16,717,815 in 2018 dollars) to finance World War I. The average rate for the rich however, was 15%. The top marginal tax rate was reduced to 58% in 1922, to 25% in 1925 and finally to 24% in 1929. In 1932 the top marginal tax rate was increased to 63% during the Great Depression and steadily increased, reaching 94% in 1944 (on income over $200,000, equivalent of $2,868,625 in 2018 dollars). During World War II, Congress introduced payroll withholding and quarterly tax payments. Tax rate reductions Following World War II tax increases, top marginal individual tax rates stayed near or above 90%, and the effective tax rate at 70% for the highest incomes (few paid the top rate), until 1964 when the top marginal tax rate was lowered to 70%. Kennedy explicitly called for a top rate of 65 percent, but added that it should be set at 70 percent if certain deductions were not phased out at the top of the income scale. The top marginal tax rate was lowered to 50% in 1982 and