Nebraska Republican Senator Norris Brown publicly decried the Court's decision in "Pollock", and proposed a constitutional amendment to remove the requirement that certain income taxes to be apportioned among the states by population. Brown's proposal would be ratified in 1913 as the Sixteenth Amendment. The Sixteenth Amendment removed the requirement for "those income taxes deemed to be direct" in substance (such as taxes on income from property) to be apportioned among the states according to population. Thus, the effect of the "Pollock" decision has indeed been overturned by the Sixteenth Amendment. The Revenue Act of 1913, which greatly lowered tariffs and implemented a federal income tax, was enacted shortly after the Sixteenth Amendment was ratified.