Next, the quarrels arising out of the apportionment of labour were bitter, constant, and savage.

The constitutional character of the tax, when levied without apportionment among the States of the Union, was once more fully argued out in the Supreme Court, which in 1880 reaffirmed its decision of 1789, that a tax on incomes was not a direct tax.

It will be well, however, to consider briefly in the first instance the different question of its apportionment between places.