Prior to the adoption of the 16th amendment, in Pollock v. Farmers' Loan and Trust Co, the Supreme Court held that:

		a. an unapportioned tax on the income from land is not a direct tax, and therefore constitutional.
		b. an unapportioned tax on the income from land is a direct tax, and therefore unconstitutional.
		c. an unapportioned tax on the income of land is an indirect tax, and therefore constitutional.
		d. an unapportioned tax on the income of land is indirect tax, and therefore unconstitutional.