Prior to the 16th Amendment, a federal income tax was technically illegal, as stated in Article I, Section 9 of the Constitution: “No capitation, or other direct tax , will be imposed, unless it is proportional to the enumeration of the censors here before ordered to be carried out. Therefore, the federal government had to rely on land sales, excise taxes, and tariffs to raise revenue. In times of crisis, however, these measures are simply not enough. During the Civil War, when the Union was in desperate need of funds, Congress passed the Revenue Act (1861), which included a provision for the nation's first income tax. By necessity, the Supreme Court overlooked the unconstitutionality of the act. The first rate was a 3% tax on all income above $800, or $21,000 in 2013 dollars, but in 1862 Congress changed the law and introduced a tiered system, with a 3% tax on all income up to $10,000 and a 5% tax on any amount above that amount. Additionally, the duty was deducted directly from the worker's paycheck so they never lost the money. Congress knew it could not collect the blatantly unconstitutional tax any more than was necessary, so in 1872, a few years after the war ended, the Revenue Act was repealed. However, the idea of ​​an income tax could not be abolished. There were many, especially farmers in the South and West, who believed that the wealthy bankers and industrialists of the East were not paying their fair share. At the urging of these malcontents, Congress passed another income tax bill in 1894 that imposed a 2% tax on all income over $4,000, or $21,000 in 2013 dollars. The Supreme Court immediately declared unconstitutional. This action has not yet killed the idea, and progressive...... middle of paper......place? Tax Policy Center, September 13, 2011. Web. January 29, 2014. “History of the 16th Amendment.” Desert Sands Educational Foundation, nd Web. "Ratification of the 16th Amendment." United States House of Representatives: History, Art, and Archives. Np, nd Web. January 28, 2014. “16th Amendment to the United States Constitution: Federal Income Tax (1913).” Our Documents and Web. January 28, 2014. .Skousen, W. Cleon. “History of the 16th Amendment.” Conservative of recent times. Np, nd Web. January 28. 2014. .