Income tax in the United States income and tax it, so long as it acts within its constitutional authority, which includes not only the Sixteenth Amendment but also Article I, Sections 8 and 9." Similarly, in "Penn Mutual Indemnity Co. v. Commissioner", the United States Court of Appeals for the Third Circuit indicated that Congress could properly impose the federal income tax on a receipt of money, regardless of what that receipt of money is called: It could well be argued that the tax involved here [an income tax] is an "excise tax" based upon the receipt of money by the taxpayer. It certainly is not
Working Tax Credit Prime Minister Tony Blair also apologised to Parliament over the incident. The Working Tax Credit scheme was subject to much criticism, particularly in the wake of the difficulties surrounding its implementation. Criticism focused on the way that credits are calculated on an annual basis, leading to overpayment, followed by large demands for repayment, which those on low income may find difficult to meet. David Harker, chief executive of Citizens Advice, commented "This is an untenable system. An annualised system doesn't provide the stability of income required by low income families." In addition, the scheme was accused of being over-complicated and