Internal Revenue Service
In 1894, Congress passed the Wilson-Gorman Tariff. It reduced the  Tariffs on certain imports into the United States. However, it made up for this by charging  a 2% direct income tax. The Supreme Court, in Pollock v. Farmers' Loan & Trust Co ruled the income tax unconstitutional a year later. The Court ruled that the Constitution did not allow an income tax without apportionment among the states.