Since the income tax may be imposed on income from whatever source and without regard to any apportionment requirement (by virtue of the wording of the 16th Amendment), an income tax cannot be treated as a direct tax (as income taxes on income from property were so treated in the "Pollock" case). Essentially, all income taxes after the Sixteenth Amendment are again treated as indirect taxes. Subsequent lower court cases have interpreted the "Brushaber" decision ("the confusion is not inherent, but rather arises from the conclusion ... this erroneous assumption") and the Sixteenth Amendment as standing for the rule that the Amendment allows a direct tax on "wages, salaries, commissions, etc. without apportionment."