In 1913 the 16th Amendment was arguably ratified. This amendment did not repeal any other section of the Constitution. However, according to the Supreme Court, in the 1911 case of Flint vs. Stone Tracy Co., the 16th Amendment did allow for theCorporate Income Tax to be categorized as an excise tax, measured by income, "on the privilege of doing business in corporate form."

In the case of Murphy vs. IRS (2005) the Supreme Court stated "The Sixteenth Amendment simply does not authorize the Congress to tax as "incomes" every sort of revenue a taxpayer may receive."

Here, and elsewhere, the courts have admitted that not all "incomes" are taxable, and Congress cannot make a thing income when it is not income. We can then infer the meaning of the term "income," as it was used at the time of the so called ratification of the 16th Amendment, it was corporate gains. Money that is derived from the trade of one's skill and time is not income in such amendment's sense. It is therefore a direct tax on the individual and direct taxes are unconstitutional if not apportioned to the states. The Supreme Court has dictated the legislature cannot be consistent with the Constitution if it tries to change the original meaning of the term income. Either way, direct taxation of the people without apportionment to the states is unconstitutional, and therefore, is illegal.

Then came the Fourteenth Amendment which created a totally new class of citizen, the federal or United States citizen. The Fourteenth Amendment also granted (or rather imposed) that no state could deny a United States citizen equal protection of the laws including the laws of taxation.

The 14th Amendment also caused a change in the hierarchy of citizenship from the superior State citizen to the current and inferior federal citizen. which now creates the concept of "dual citizenship". The concept of "dual citizenship" causes a bit of a misunderstanding for many. The term "United States" when used in the Constitution means the many states of the Union. However, when the term "United States" is used in federal statutes, the aforementioned federal zone now applies.

The federal government has absolutely NO police/enforcement power outside of the federal zone. So, a mechanism had to be put into place that created a nexus between the federal government and the people residing within the states of the Union. This nexus was accomplished with the Fourteenth Amendment. Due to the Fourteenth Amendment, the federal government now assumes all members of society are Fourteenth Amendment citizens and now the federal government, instead of the Constitution, ensures "their" citizen's rights and obligations are protected.