Three years after ratification of the Sixteenth Amendment, the United States Supreme Court rendered its decision in the case of "Brushaber v. Union Pacific Railroad". In "Brushaber", the Court reviewed the history of the dichotomy between excises (indirect taxes) and direct taxes. The "Brushaber" Court noted that the 1913 Income Tax Act was written as an indirect tax and did not violate the rule of uniformity and so it was not written as a direct tax and thus was not subject to the rule of apportionment. The Court summarized what it had decided in "Pollock" and then went on to state the effect of the Sixteenth Amendment with respect to income taxes: