In 1894, Congress passed the Wilson-Gorman Tariff. It reduced the Tariffs on certain imports into the United States. However, it made up for this by charging a 2% direct income tax. The Supreme Court, in "Pollock v. Farmers' Loan & Trust Co" ruled the income tax unconstitutional a year later. The Court ruled that the Constitution did not allow an income tax without apportionment among the states.