This income tax would not be removed until 1870. But soon after the Income Tax of 1894 would come which allowed for a direct, peacetime levy on personal profits gained from business transactions or employment, such as shares of shock (Study.com). One year after the Income Tax of 1894 the Supreme Court case of Pollock v. Farmer's Loan and Trust Co. 1895 would hit center stage in the world of income tax. This one court case is the reason that the 16th Amendment had become a need for a nation. This case “took a new and surprising tack which made this, after the Dred Scott case, the most widely criticized decision in the Court`s history ("Supreme Court Case Pollock v. Farmer's Loan and Trust Co. 1895.").” The case was heard twice. The first hearing, by a vote of six to two, stated that in order to be constitutional the tax on income must be apportioned according to population. The second hearing, by a vote of five to four stated that taxes on income from personal property were direct taxes therefore income taxes from land are unconstitutional. This would lead to an uproar in the country, “though many conservatives were happy at what they considered a blow to "Populism." Because of this decision, the Sixteenth Amendment had to be passed in 1913 before income taxes could be levied ("Supreme Court Case Pollock v. Farmer's Loan and Trust Co.