Congress had previously introduced an income tax during the American Civil War, but this tax had been repealed in 1872. In 1894, Congress passed the Wilson-Gorman Tariff Act, which lowered tariff rates and made up for some of the lost revenue by introducing taxes on income, corporate profits, gifts, and inheritances. Chief Justice Melville Fuller's majority opinion in "Pollock" held that a federal tax on income derived from property was unconstitutional when it was not apportioned among the states according to representation in the United States House of Representatives. Fuller also held that federal taxation of interest earned on certain state bonds violated the doctrine of intergovernmental tax immunity. In one dissent, Associate Justice Henry Billings Brown wrote that the majority opinion "involves nothing less than the surrender of the taxing power to the moneyed class."